Privacy Policy

01 Who we are

NeedleSpotter Inc. is a New Jersey-based company that operates Together4Cancer® Beacon™, an educational cancer navigation and decision-support platform.

Beacon is designed to help people affected by cancer and their caregivers organize information, prepare for conversations with healthcare professionals, identify questions worth discussing, and navigate healthcare decisions.

NeedleSpotter Inc. determines how personal information is processed in connection with its direct-to-consumer Beacon service.

Beacon may also be made available through hospitals, healthcare organizations, nonprofits, employers, research programs, educational programs, or other organizations. Additional privacy terms or agreements may apply in those circumstances.

02 Health information and different privacy laws

Beacon may process information about cancer diagnoses, testing, treatments, symptoms, medications, preferences, medical records, and other healthcare matters.

We treat this information as sensitive whether applicable law refers to it as health information, consumer health data, sensitive personal information, protected health information, or another term.

Different privacy laws may apply depending on how and where you use Beacon.

Where Beacon is provided on behalf of a healthcare organization under an arrangement that requires a Business Associate Agreement or other healthcare privacy agreement, those additional requirements will apply to the information covered by that arrangement.

Nothing in this Privacy Policy limits privacy rights that cannot legally be waived.

03 Information we collect

The information we collect depends on how you interact with Beacon.

A.Account and contact information

We may collect:

• your name;
• email address;
• ZIP or postal code;
• account identifiers;
• authentication information;
• access status;
• subscription or access period;
• purchase and renewal status;
• sponsor or access source, where applicable;
• communication preferences; and
• records relating to your acceptance of our Terms of Use and Privacy Policy.

We use this information to create and administer access, authenticate users, communicate with you, manage purchases and access periods, provide support, and maintain necessary business records.

ZIP or postal code is used to provide location-relevant resources and for aggregate geographic analysis.

Some account, purchase, access, and communication information may be maintained through customer relationship management systems such as GoHighLevel (HighLevel).

B.Health and clinical information

When you use Beacon, you may provide information including:

• cancer type;
• diagnosis;
• stage;
• pathology findings;
• imaging findings;
• biomarker or genomic testing;
• laboratory results;
• proposed or previous treatments;
• medications;
• treatment response;
• symptoms or side effects;
• medical history;
• healthcare providers or care-team information;
• testing status;
• clinical-trial considerations;
• treatment goals;
• questions or concerns;
• personal preferences and priorities;
• financial or logistical concerns;
• work or family circumstances;
• caregiving circumstances;
• emotional or supportive-care concerns; and
• other information you choose to discuss with Beacon.

We use this information to provide the personalized educational and navigation functions you request.

C.Medical records and documents

Beacon may allow you to upload healthcare documents such as:

• pathology reports;
• imaging reports;
• laboratory results;
• molecular or genomic testing reports;
• clinical notes;
• treatment summaries;
• medication lists;
• visit summaries; and
• other medical documents.

Medical records may contain identifiers such as your name, date of birth, medical-record number, healthcare provider, or other personal information.

We do not require you to remove these identifiers unless Beacon specifically instructs you to do so.

You should provide only information reasonably necessary for the purpose for which you are using Beacon.

D.Conversations and contextual information

We process information you provide during Beacon conversations so that Beacon can respond to your questions and personalize your navigation experience.

Where continuity features are available, Beacon may retain selected contextual information, summaries, profile information, preferences, or other information from previous interactions to make later interactions more useful.

Contextual memory and verbatim conversation history are not necessarily the same thing and may be stored differently.

Beacon should not be treated as a permanent medical-record system or guaranteed archive of every conversation.

E.Generated information

Beacon may generate or store information derived from your interactions, including:

• summaries;
• decision maps;
• question lists;
• Decision Readiness Records™;
• Pre-Treatment Care Team Briefs™;
• navigation status;
• identified information or decision gaps;
• contextual summaries; and
• other personalized outputs.

Because these outputs may reveal information about your health, we treat personalized Beacon outputs as sensitive information.

F.Product and usage information

We may collect limited information about how Beacon is used, including:

• login activity;
• session timestamps;
• stages or features accessed;
• stage completion;
• number of messages exchanged;
• document-generation events;
• feature interactions;
• technical errors;
• system performance; and
• other information necessary to operate, secure, troubleshoot, and improve Beacon.

Some of this information may be associated with your account where necessary to provide continuity, administer access, troubleshoot problems, or understand how the Service is functioning.

G.Technical information

We may automatically receive technical information including:

• IP address;
• browser type;
• device type;
• operating system;
• referring webpage;
• approximate location derived from IP address;
• timestamps;
• cookies or similar identifiers; and
• technical or security logs.

H.Purchase and transaction information

If you purchase Beacon, we may receive information including:

• transaction date;
• amount;
• currency;
• payment status;
• product purchased;
• billing contact information; and
• identifiers associated with the transaction.

Payment-card information is processed by payment processors such as Stripe. NeedleSpotter Inc. does not intentionally store complete payment-card numbers within Beacon.

I.Communications with us

If you contact us, we may retain:

• your email address;
• the content of your communication;
• customer-support history;
• feedback; and
• other information you choose to provide.

04 Consumer health data

Beacon may collect information that identifies or may reasonably reveal information about your past, present, or future health.

Categories of health information we may collect

Depending on how you use Beacon, this may include:

• diseases, diagnoses, or health conditions;
• cancer diagnosis and stage;
• treatment information;
• medication information;
• laboratory results;
• pathology information;
• imaging information;
• biomarker or genomic information;
• symptoms and side effects;
• medical procedures or interventions;
• healthcare providers or facilities;
• treatment goals and preferences;
• health-related questions;
• information contained in medical records;
• health-related information generated from your use of Beacon; and
• information that could reasonably be used to infer health-related circumstances.

Sources of health information

We generally receive this information:

• directly from you;
• from documents you choose to upload;
• from another person using Beacon on your behalf with appropriate authorization;
• from information generated through your interactions with Beacon; or
• where expressly disclosed and authorized, from an institution involved in providing your Beacon access.

We do not independently request medical records from your healthcare providers unless a particular service expressly informs you that it does so and any required authorization has been obtained.

Why we collect and use health information

We use health information to:

• provide the Beacon experience you request;
• interpret information you provide;
• answer questions;
• personalize educational content;
• organize information relating to your care;
• identify potential information or decision gaps;
• suggest issues or questions that may be worth discussing with your healthcare team;
• generate personalized documents;
• maintain contextual continuity where available;
• troubleshoot technical problems;
• protect Beacon’s security and integrity;
• perform limited quality or safety review; and
• comply with applicable legal obligations.

Who may process health information

Health information may be processed by service providers necessary to operate Beacon, including providers of:

• artificial-intelligence processing;
• retrieval and search infrastructure;
• databases and data storage;
• cloud hosting;
• authentication;
• security; and
• technical operations.

These providers process information in connection with providing services to NeedleSpotter Inc.

05 How we use your information

We may use information to:

Provide Beacon

This includes authenticating you, processing the information you provide, answering questions, personalizing Beacon, generating documents, and providing the navigation features you request.

Maintain continuity

Where available, we may retain selected contextual information so that later Beacon interactions can reflect information you have previously provided.

Manage access and customer relationships

We may use your account, purchase, renewal, access, and contact information to:

• grant or maintain access;
• administer your access period;
• process renewals where applicable;
• send access information;
• provide customer support; and
• maintain appropriate customer records.

Operate and secure Beacon

We may use information to:

• maintain the Service;
• detect errors;
• troubleshoot technical issues;
• prevent fraud or unauthorized access;
• investigate security incidents;
• enforce our Terms of Use; and
• maintain service reliability.

Improve Beacon

We may use usage statistics, aggregate information, de-identified information, feedback, and limited quality-assurance review to understand how Beacon performs and improve the Service.

A limited number of authorized personnel may access information when reasonably necessary to:

• respond to a support request;
• diagnose a technical problem;
• investigate security or potential misuse;
• comply with legal obligations; or
• conduct targeted quality or safety review.

Access is limited according to legitimate business need and purpose.

Communicate with you

We may use contact information to send:

• access links and authentication messages;
• purchase confirmations;
• account notifications;
• access or renewal information;
• customer-support communications;
• security notices;
• material service or policy changes; and
• educational or promotional communications where you have subscribed or where otherwise permitted by law.

You can unsubscribe from marketing communications without losing necessary transactional or service communications.

06 Artificial intelligence processing

Beacon uses artificial intelligence and related technologies to provide personalized educational responses and analyze information you provide.

Information submitted during a Beacon interaction may therefore be transmitted to an AI service provider for processing.

Our current AI and retrieval infrastructure may include commercial services provided by Anthropic and Voyage AI.

AI processing occurs server-side through a secure proxy. Your clinical session content is not exposed to third-party scripts running in your browser.

We seek to minimize unnecessary direct identifiers transmitted to AI providers where technically feasible.

However, if a medical document or information you provide contains personal identifiers, those identifiers may be included in the information processed by the AI system unless they are removed before processing.

AI model training

Commercial AI providers process information according to our service configuration, contractual arrangements, their applicable service terms, and applicable law.

If we introduce a materially different use of identifiable or personalized health information for AI model training, we will update this Privacy Policy and obtain additional consent where required.

07 Service providers

We use third-party providers to operate Beacon. Current providers may include:

• Anthropic — artificial-intelligence processing
• Voyage AI — retrieval and related AI infrastructure
• Supabase — database, storage, authentication, access management, and related backend infrastructure
• Vercel — application hosting and technical infrastructure
• GoHighLevel (HighLevel/GHL) — customer relationship management, website or funnel infrastructure, access workflows, customer communications, and marketing operations
• GitHub — source-code hosting, software development, version control, and deployment automation
• Google — website analytics and advertising measurement
• Meta Platforms — advertising and conversion measurement
• Resend — transactional email delivery
• Stripe — payment processing
• Other providers — security, infrastructure, communications, or technical services necessary to operate Beacon

Service providers may receive information reasonably necessary to perform the services they provide.

GoHighLevel

GoHighLevel may process information such as:

• name;
• email address;
• contact information;
• purchase status;
• access or renewal status;
• communication preferences;
• customer-support or communication history; and
• website or funnel activity.

We do not intentionally place the substantive content of personalized Beacon medical conversations or uploaded medical records into GoHighLevel for advertising purposes.

GitHub

GitHub is used for software development and related technical operations.

GitHub is not intentionally used as a repository for Beacon users’ medical records, personalized Beacon conversations, or clinical information.

08 Analytics, cookies, and similar technologies

Our public-facing websites use cookies, pixels, analytics technologies, and similar tools for:

• essential website functions;
• authentication and security;
• understanding website usage;
• measuring performance;
• remembering preferences;
• understanding how visitors find Beacon; and
• measuring advertising effectiveness.

These technologies include services provided by Google and Meta.

Depending on your browser, device, location, and available site controls, you may be able to limit certain cookies or advertising technologies. Disabling some technologies may affect website functionality.

You can opt out of Google Analytics using the Google Analytics Opt-out Browser Add-on, and manage advertising preferences through your Meta ad-preferences settings.

Cookies set by our website software itself, rather than by analytics or advertising providers, are described in Section C2.

09 Advertising partners: what they may see — and what we do not intentionally send

We advertise Beacon through services provided by Meta Platforms, Inc., including Facebook and Instagram, and Google LLC.

Advertising and measurement technologies are used on selected public-facing marketing, informational, or checkout pages.

What advertising and measurement providers may receive

Depending on the technology used, configuration, privacy choices, and applicable law, advertising or measurement providers may receive information such as:

• that a public-facing webpage was visited;
• page URL or title;
• that an advertisement was clicked;
• advertising campaign or referral information;
• browser and device information;
• IP address;
• cookies or advertising identifiers;
• event date and time;
• checkout or conversion events;
• transaction amount and currency for purchase measurement; and
• where configured, hashed or otherwise protected identifiers used for attribution or measurement.

Hashing an identifier does not necessarily make that information anonymous, so we treat hashed identifiers as personal information where applicable.

Cancer-related website context

What we do not intentionally send to advertising platforms

We do not intentionally provide Meta, Google, or other advertising platforms with the substantive content of your personalized Beacon use for advertising purposes, including:

• Beacon conversation text;
• questions asked within personalized Beacon sessions;
• medical records or documents you upload;
• information extracted from uploaded medical records;
• specific cancer diagnosis or stage provided within Beacon;
• pathology results;
• imaging results;
• biomarker or genomic results;
• laboratory results;
• medications;
• treatment history;
• symptoms or side effects you describe;
• detailed treatment preferences;
• Decision Readiness Records™;
• Pre-Treatment Care Team Briefs™;
• personalized decision maps; or
• other detailed clinical information provided within Beacon.

We do not intentionally use the content of your uploaded medical records or personalized Beacon conversations to create advertising audiences.

Sale and sharing

We do not sell consumer health data. We do not sell personal information for money.

Some privacy laws may classify certain disclosures to advertising or measurement providers as “sharing” or “sale” even where no money is exchanged.

Where applicable law gives you the right to opt out of such processing, you may exercise that right as described in Section 19.

10 Pharmaceutical, healthcare, and educational sponsors

Together4Cancer may receive support from pharmaceutical companies, healthcare organizations, foundations, nonprofits, or other organizations through educational grants, sponsorships, or commercial arrangements.

We may create aggregate or de-identified statistics to understand:

• how groups of people use Beacon;
• where patients commonly experience information or decision gaps;
• which navigation topics are commonly encountered; and
• how educational programs perform at a population level.

For example, an aggregate insight might describe the percentage of patients within a sufficiently large group who indicated that a particular type of testing had not yet been ordered before their first treatment appointment.

We may share appropriately aggregated or de-identified insights with educational sponsors, healthcare organizations, or other partners.

We take reasonable steps to avoid reporting groups so small that an individual could reasonably be identified from the information provided.

Sponsor measurement technologies

In the future, sponsor-provided measurement tags may be placed on selected educational pages to measure the reach of grant-funded educational content. We will update this Privacy Policy before implementing any sponsor tracking and will disclose the specific nature of that tracking at the point of delivery.

If a specific sponsored program involves materially different data practices, we will provide additional disclosure before those practices apply.

11 De-identified and aggregate information

We may create aggregate or de-identified information that is not reasonably linkable to a particular individual.

We may use this information to:

• improve Beacon;
• understand navigation and decision patterns;
• evaluate product performance;
• conduct internal analytics;
• identify population-level information gaps;
• support educational programs;
• prepare reports; and
• communicate population-level insights.

Where required by applicable law, we maintain de-identified information in de-identified form and do not attempt to re-identify it except as permitted for purposes such as testing whether de-identification methods are effective.

12 Payment information

Payments may be processed by third-party payment providers such as Stripe.

Payment processors may collect information such as:

• name;
• billing information;
• email address;
• payment-card information; and
• transaction information.

NeedleSpotter Inc. generally receives information necessary to administer your purchase, such as payment status and transaction details, but does not intentionally store your complete payment-card number within Beacon.

Payment processors process information according to their own privacy policies and legal obligations.

13 Communications and marketing

We may use communication and customer-management providers, including GoHighLevel and transactional email providers, to send or manage:

• account and access communications;
• purchase or renewal information;
• service notifications;
• customer-support communications; and
• educational or promotional communications.

If you opt in to educational or promotional communications, you may unsubscribe at any time using the unsubscribe link provided or by contacting us.

Unsubscribing from marketing communications does not prevent us from sending:

• authentication messages;
• transactional communications;
• security messages;
• account notifications;
• legal notices; or
• other communications necessary to operate your Beacon access.

We do not intentionally provide the substantive content of your medical records or personalized Beacon conversations to marketing communications providers for their own advertising purposes.

14 Conversation history, context, and memory

Beacon may retain information from your interactions in different ways. For example:

• some information may be retained as account or profile context;
• some information may be summarized to support continuity;
• some generated documents may be available for a period of time;
• some recent conversation history may be available through particular features; and
• complete verbatim conversation history may not be permanently stored or retrievable.

Contextual memory does not mean that Beacon maintains a permanent verbatim record of every conversation.

15 Data retention

We retain different categories of information for different periods depending on why the information is needed.

We may retain information for as long as reasonably necessary to:

• provide Beacon;
• maintain your account;
• administer your access period;
• maintain contextual continuity where enabled;
• fulfill transactions;
• provide customer support;
• maintain security;
• detect or prevent fraud and misuse;
• comply with legal, tax, or accounting requirements;
• resolve disputes; and
• enforce our agreements.

Account information, contextual information, uploaded documents, generated outputs, transaction records, communications, and technical logs may have different retention periods.

When you submit a valid deletion request, we will delete, de-identify, or otherwise handle information as required by applicable law and subject to legally permitted exceptions.

Information may remain temporarily in secure backups after deletion from active systems and will be removed according to applicable backup and data-lifecycle procedures.

We generally seek to respond to verified privacy requests within 30 days, and otherwise within the period required by applicable law.

16 Data security

We use administrative, technical, and organizational safeguards designed to protect personal and health information.

Depending on the system involved, safeguards may include:

• encryption in transit using SSL/TLS;
• encryption at rest where supported;
• authentication through time-limited secure links sent to your email address;
• restricted access;
• row-level security on database tables;
• secure server-side processing, so clinical session content is not exposed to the browser;
• infrastructure and security monitoring; and
• limitations on personnel access to sensitive information.

Access to sensitive information is limited to people and systems with a legitimate need for that access.

No internet-connected system can guarantee absolute security.

If we discover unauthorized access, acquisition, disclosure, or loss of information that requires notification under applicable law, we will provide the notifications required by law.

17 Your privacy rights

Regardless of where you live, you may contact us to request:

• access to personal information we maintain about you;
• correction of inaccurate information;
• deletion of your account and associated information, subject to permitted exceptions;
• information about our privacy practices; or
• withdrawal from marketing communications.

Depending on applicable law, you may have additional rights, including the right to:

• confirm whether we process information about you;
• obtain a portable copy of certain information;
• withdraw consent where consent is the applicable basis for processing;
• opt out of certain targeted advertising;
• opt out of certain sales or sharing of personal information;
• limit certain uses of sensitive information;
• identify entities with whom certain information has been shared;
• appeal a decision concerning a privacy request; and
• complain to an appropriate regulator.

We may need to verify your identity before fulfilling certain requests.

We will not discriminate against you for exercising a legally protected privacy right.

18 Additional consumer health data rights

Depending on where you live, laws governing consumer health data may provide rights in addition to ordinary personal-information rights.

Where applicable, these may include the right to:

• confirm whether we collect, use, share, or sell consumer health data concerning you;
• access consumer health data;
• obtain information about the categories or entities with whom consumer health data has been shared;
• request deletion;
• withdraw consent to future collection or sharing where consent is legally required;
• appeal certain decisions concerning privacy requests; and
• obtain other information required by applicable law.

We do not sell consumer health data.

Where applicable law requires us to transmit an appropriate deletion request to processors or other entities holding consumer health data on our behalf, we will do so.

19 U.S. state privacy rights

Residents of California, New Jersey, Washington, and other states may have additional privacy rights if the applicable state privacy law applies to NeedleSpotter Inc. or a particular processing activity.

Depending on the law and circumstances, health condition, treatment, diagnosis, genetic information, and other healthcare information may be treated as sensitive personal information or consumer health data.

We do not sell personal information for money.

Certain advertising or measurement activities may be classified as “sharing” or “sale” under some state privacy laws even where no money is exchanged.

20 Children and minors

Beacon’s direct-to-consumer service is intended for people age 18 or older.

We do not knowingly permit a person under 18 to independently create or purchase a Beacon account.

An adult may use Beacon in connection with a minor’s care where the adult has appropriate authority or permission.

If you believe a person under 18 has independently provided personal information to Beacon in violation of this policy, contact contact@together4cancer.com. We will investigate and take appropriate action.

We do not knowingly use information relating to children for targeted advertising.

21 Institutional or sponsored access

Beacon may be made available through:

• hospitals;
• healthcare organizations;
• nonprofit organizations;
• employers;
• educational programs;
• research programs;
• sponsors; or
• other institutions.

Depending on the arrangement:

• the organization may pay for or sponsor your access;
• the Beacon configuration may differ from the direct-to-consumer version;
• authentication may operate differently;
• session history or contextual memory may operate differently;
• retention periods may differ;
• the organization may receive aggregate usage information; or
• additional privacy notices or agreements may apply.

If an organization will receive identifiable information about your use of Beacon, we will provide any additional disclosure, consent, or authorization required by applicable law.

22 Legal disclosures

We may disclose information where reasonably necessary to:

• comply with applicable law, regulation, legal process, or enforceable governmental request;
• protect the rights, safety, or security of Beacon, NeedleSpotter Inc., our users, or others;
• investigate fraud, misuse, or security incidents;
• enforce our Terms of Use; or
• establish, exercise, or defend legal claims.

Where legally permitted and practicable, we seek to limit disclosures to information reasonably necessary for the relevant purpose.

23 Corporate transactions

If NeedleSpotter Inc. is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction.

Any successor that receives personal information through such a transaction will be subject to applicable privacy obligations.

If a transaction materially changes how sensitive health information will be used, we will provide additional notice or obtain consent where required by applicable law.

24 International users and data transfers

NeedleSpotter Inc. is based in the United States.

Beacon and its service providers may process information in the United States or other countries.

If you use Beacon from outside the United States, information may therefore be transferred to jurisdictions whose privacy laws differ from those where you live.

Where applicable law requires specific safeguards or transfer mechanisms, we will use appropriate measures.

Users in jurisdictions providing additional privacy rights may contact us to exercise rights applicable to them.

25 Third-party websites and resources

Beacon may link to:

• healthcare organizations;
• clinical-trial registries;
• professional societies;
• government resources;
• advocacy organizations;
• publications; or
• other external services.

This Privacy Policy does not govern the privacy practices of third parties you choose to visit or interact with.

Review the privacy policies of those organizations before providing information directly to them.

26 Changes to this Privacy Policy

We may update this Privacy Policy as:

• Beacon changes;
• technology changes;
• service providers change;
• our business practices change; or
• applicable laws or regulatory requirements change.

The current version will display its Last Updated date.

Additional tools and products may be added under the Together4Cancer® umbrella over time. Each new product will be covered by this Privacy Policy. Where a new product involves meaningfully different data practices, we will update this Privacy Policy and notify users accordingly.

If we make a material change that significantly affects how sensitive or health information is collected, used, or shared, we will provide additional notice where appropriate or required.

Where applicable law requires additional consent before we collect, use, or share health information for a materially new purpose, we will obtain that consent before beginning the new processing.

27 Contact us

Together4Cancer® Beacon™ is operated by NeedleSpotter Inc., New Jersey, United States.

For privacy questions, concerns, access requests, correction requests, deletion requests, or other privacy matters: contact@together4cancer.com