🔒 Privacy Policy — HIPAA · HITECH · 21st Century Cures Act · CCPA Aligned DOC-PRIVACY-001 · v1.0 · Effective 2026-04-19
Rx
MyRxWallet North America Corporation
Sovereign Health Infrastructure · Wyoming Corporation
Privacy Policy
How we collect, use, protect, and share information about you when you use the MyRxWallet platform and services.
Document IDDOC-PRIVACY-001
Version1.0
Effective DateApril 19, 2026
Last ReviewedApril 19, 2026
🔒 Patient Data Is Never Sold · Never Monetized Without Consent
Section 01
Overview
Our Core Privacy Commitment

MyRxWallet was built on a single foundational principle: your health data belongs to you. We do not sell your data. We do not monetize your health information without your explicit consent and financial participation. We are a conduit, not a custodian.

This Privacy Policy ("Policy") applies to MyRxWallet North America Corporation ("MyRxWallet," "Company," "we," "us," "our"), a Wyoming corporation operating the MyRxWallet health information technology platform accessible at https://myrxwallet.io and related subdomains, APIs, and mobile applications (collectively, the "Platform").

This Policy describes how we collect, use, disclose, and protect personal information — including Protected Health Information (PHI) — when you use our Platform. For information specific to HIPAA-governed health data, please also review our HIPAA Notice of Privacy Practices.

By accessing or using the Platform, you acknowledge that you have read and understand this Privacy Policy. If you do not agree with this Policy, do not use the Platform.

Section 02
Information We Collect

Account & Identity Information

When you create an account, we collect:

  • Name, email address, phone number, date of birth
  • Government-issued ID information (for identity verification, if provided)
  • Authentication credentials (password hash — we never store plain-text passwords)
  • Multi-factor authentication identifiers (phone number for SMS OTP, device tokens)
  • MyRx-ID (blockchain-based patient identifier, assigned upon enrollment)
  • National Provider Identifier (NPI) for healthcare providers signing up as providers

Protected Health Information (PHI)

If you are a patient using the Platform, we collect, store, and process PHI including:

  • Medical history, diagnoses, conditions (ICD-10), procedures (CPT)
  • Medications and prescriptions (RxNorm-coded)
  • Laboratory results (LOINC-coded), vital signs, immunizations
  • Imaging reports, diagnostic reports, clinical notes
  • Insurance and coverage information
  • Consent authorizations and revocations
  • Substance use disorder (SUD) records (governed by 42 CFR Part 2 with heightened protections)

All PHI is encrypted at rest using AES-256-GCM with HKDF-SHA256 key derivation and encrypted in transit using TLS 1.3. Our blockchain stores only cryptographic hashes — zero plain-text PHI is on-chain.

Usage & Technical Data

We automatically collect certain technical information when you use the Platform:

Data TypePurposeRetention
IP AddressSecurity, fraud prevention, geo-compliance90 days
Browser / Device TypePlatform optimization, security audit90 days
Session TokensAuthentication (JWT, 15-min access / 7-day refresh)Token lifetime
API Access LogsHIPAA audit trail (45 CFR §164.312(b))6 years
Consent Event LogsBlockchain audit trail (on-chain hashes only)Permanent on-chain
Security Incident LogsHIPAA security compliance6 years
Section 03
How We Use Your Information
PurposeLegal BasisData Used
Providing health portal servicesContract · HIPAA TreatmentPHI, Account Info
Identity verification & MFASecurity requirement · ContractPhone, Email, Device
Processing payment claimsHIPAA PaymentPHI, Insurance Info
Blockchain consent audit trailHIPAA Operations · 21CC ActConsent hashes (no PHI)
Security monitoring (Sentinel)HIPAA Security Rule · DoD STIGSession data, access logs
Platform analyticsLegitimate interest (de-identified only)Aggregated usage data
Legal compliance & reportingLegal obligation (HIPAA, ONC, CMS)As required by law
Communicating with youContract · ConsentEmail, Phone
Research (with IRB approval)HIPAA Research · Your authorizationDe-identified or authorized PHI
What We Will NEVER Do

We will never sell your personal information or PHI to advertisers, data brokers, or third parties for commercial purposes. We will never use your health data to train AI models without your explicit written authorization and financial compensation under our MyRx-Royalty program.

Section 04
Sharing & Disclosure of Information

With Your Consent

We share your information with third parties only with your explicit authorization, except as required by law. All consent grants are recorded on our blockchain audit trail and can be revoked through the Patient Portal at any time.

Business Associates

We share PHI with service providers under written Business Associate Agreements (BAAs) as required by HIPAA. These providers may only use PHI for the purposes specified in the BAA.

Legal Requirements

We may disclose information when required by law, court order, or governmental authority. We will notify you of such disclosure to the extent legally permitted.

Health Information Exchange (TEFCA/QHIN)

With your authorization, we may exchange your health records with other providers and payers through TEFCA-connected networks and payer APIs (CMS Blue Button, BCBS, UHC, Aetna, Cigna, Humana, Anthem). All exchanges are logged in your consent history.

We Do Not Sell Your Data

MyRxWallet does not sell personal information as defined under the California Consumer Privacy Act (CCPA) or any other applicable law.

Section 05
Data Security
Security ControlStandardStatus
Encryption at RestAES-256-GCM · HKDF-SHA256ACTIVE
Encryption in TransitTLS 1.3ACTIVE
Access ControlJWT · OAuth 2.0 + PKCE · RBACACTIVE
Audit LoggingHIPAA 45 CFR §164.312(b)ACTIVE
Blockchain AuditHyperledger Fabric 2.5ACTIVE
Multi-Factor AuthenticationTOTP · SMS OTP · Device ShakeACTIVE
Security MonitoringMyRx-Sentinel · DoD STIG-alignedACTIVE
Penetration TestingAnnual (planned)PLANNED
SOC 2 Type IISchellman & Company (engagement pending)IN PROGRESS

No system is 100% secure. While we implement industry-leading security measures, we cannot guarantee absolute security of your data. In the event of a breach, we will notify you as required by HIPAA within 60 days of discovery.

Section 06
Data Retention

We retain your information for the periods required by applicable law and our legitimate business purposes:

Data CategoryRetention PeriodAuthority
PHI / Medical Records6 years from date of creation or last effective date45 CFR §164.530(j)
HIPAA Audit Logs6 years45 CFR §164.312(b)
Consent RecordsPermanent (blockchain anchored)HITECH · 21CC Act
Prescriptions (EPCS)2 years (Schedule II–V)21 CFR Part 1311
SUD Records (42 CFR Part 2)Per applicable state law + patient request42 CFR Part 2
Account DataDuration of account + 3 years post-deletionLegitimate interest
Security Logs6 yearsHIPAA Security Rule

Upon account deletion, we will de-identify or delete your personal information to the extent permitted by law. Some information may be retained in anonymized form for aggregate analytics or as required by our legal obligations.

Section 07
Cookies & Tracking Technologies

We use minimal, essential cookies and local storage on the Platform:

  • Authentication tokens (JWT): Stored in localStorage to maintain your logged-in session. 15-minute access token lifespan; 7-day refresh token.
  • Theme preference: Light/dark mode preference stored in localStorage. No personal data.
  • Push notification subscription: VAPID WebPush subscription stored in IndexedDB for real-time health alerts.
  • No advertising cookies. We do not use advertising networks, ad pixels, or behavioral tracking cookies.
  • No third-party analytics trackers. We do not use Google Analytics, Facebook Pixel, or similar third-party tracking services.
Section 08
Your Privacy Rights

Depending on your location, you may have the following rights:

RightHow to ExerciseResponse Time
Access your dataPatient Portal → Medical RecordsImmediate (digital) / 30 days (formal)
Correct inaccurate dataPatient Portal → Profile or written request60 days
Delete your dataWritten request to Privacy Officer30 days (subject to legal retention requirements)
Restrict processingPatient Portal → Consents → Restrictions10 business days
Data portabilityFHIR R4 API · Patient Portal → ExportImmediate (FHIR) / 30 days (formal)
Opt out of data saleN/A — we do not sell dataN/A
Withdraw consentPatient Portal → Consents → RevokeImmediate
File a complaintinfo@myrxwallet.io or HHS OCR10 business days acknowledgment

California Residents (CCPA/CPRA): You have additional rights including the right to know, delete, correct, and opt-out of sale/sharing. We honor all CCPA/CPRA requests. To submit a verifiable consumer request, contact info@myrxwallet.io or 702.546.8686.

Section 09
Children's Privacy (COPPA)

The MyRxWallet Platform is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent as required by the Children's Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506.

For minors aged 13–17, a parent or legal guardian must authorize account creation and maintain oversight of the account. Certain sensitive health records (e.g., SUD treatment, reproductive health, family planning) may be maintained confidential from parents as permitted by applicable state law.

If you believe we have inadvertently collected information from a child under 13, please contact us immediately at info@myrxwallet.io and we will delete such information promptly.

Section 10
Changes to This Policy

We reserve the right to update this Privacy Policy at any time. When we make material changes, we will:

  • Update the "Effective Date" at the top of this Policy.
  • Notify you through the Patient Portal with a prominent notice.
  • Send an email notification to your registered address for material changes.
  • Provide a 30-day notice period before material changes take effect for existing users.

Your continued use of the Platform after the effective date of the updated Policy constitutes your acceptance of the changes.

Section 11
Contact Us
ContactDetails
Privacy OfficerOlivia Trinh, Chairman & CEO
Emailinfo@myrxwallet.io
Phone702.546.8686
CompanyMyRxWallet North America Corporation
IncorporationWyoming, USA · EIN 99-2045560
FHIR Endpointhttps://ehr.myrxwallet.io/fhir/r4