Effective: June 10, 2026

This statement explains how RoundSmarter LLC (operating as “Round
Smarter”) handles information when our platform is used by healthcare
providers in skilled nursing and long-term acute care settings.

Round Smarter is a
HIPAA Business Associate

Round Smarter is a Business Associate as defined by the Health
Insurance Portability and Accountability Act (HIPAA). We do not have a
direct treatment relationship with patients. We provide our platform to
healthcare organizations (the Covered Entities) under written Business
Associate Agreements (BAAs) that govern how we may use and disclose
Protected Health Information (PHI) on their behalf.

If you are a patient with questions about your health information,
please contact the healthcare organization that treats you. Your
provider can route privacy-rights requests to us through our BAA
process.

Information We Process

Round Smarter processes the following categories of information on
behalf of the healthcare organizations that contract with us:

Microphone and Audio
Recordings

The Round Smarter mobile app can record short clinical audio during
rounding when a provider chooses to start a recording. Microphone access
is used solely for this purpose; the app does not record in the
background or without an explicit provider action. Recordings are
uploaded to our HIPAA-compliant environment over TLS and processed into
provider-reviewed clinical documentation. A recording is deleted from
the device once it has been successfully uploaded and persisted
server-side, and the server-side audio is retained only as long as
needed to produce and confirm the resulting documentation, after which
it is deleted. Audio is treated as PHI; it is never used for advertising
and never sold.

How We Store and Protect
Information

Retention

Clinical data retrieved from PointClickCare is held under a 90-day
rolling retention window per (patient, data type). A record’s
last_confirmed_at timestamp is refreshed each time
PointClickCare re-emits the same record through a polling cycle or
webhook event. Records not refreshed within 90 days are deleted by a
daily sweep job. AI-derived clinical summaries follow the same 90-day
window.

When a patient is discharged or a facility off-boards from Round
Smarter, retained data for the affected scope is purged ahead of the
normal sweep.

How We Use Information

We use the information described above strictly to operate the Round
Smarter platform on behalf of the Covered Entities we serve — generating
clinical briefs and AI-assisted documentation, retrieving the clinical
data those tasks require, and providing the authenticated user interface
that displays them. We do not sell PHI. We do not use PHI for
advertising. Aggregate, fully de-identified statistics derived from
platform operation may be used for system improvement and quality
monitoring; nothing released externally identifies any individual.

Sharing

We do not share PHI outside of:

Provider Rights and
Account Information

Authorized providers using Round Smarter may request a copy of their
account information, request correction of inaccurate account
information, or close their account by emailing admin@roundsmarter.com.
Requests related to PHI are handled through the Covered Entity, per the
governing BAA.

Security Incidents

In the event of a security incident affecting PHI, Round Smarter will
notify the affected Covered Entity in accordance with the terms of the
governing BAA and applicable law.

Children

Round Smarter is a professional tool intended solely for licensed
healthcare providers and authorized facility staff. It is not directed
to, or intended for use by, children, and we do not knowingly collect
personal information directly from anyone under the age of 16. Any
information about minors that appears in the platform is patient clinical
data processed on behalf of a Covered Entity under a BAA — not
information collected from a child user.

Contact

For privacy questions or to report a privacy concern, contact:

Email: admin@roundsmarter.com (subject
line: “Privacy”)

Updates to This Statement

We may update this statement as our practices evolve. Material
changes will be reflected in the effective date at the top of this page
and communicated to the Covered Entities we serve through the BAA
process.


Round Smarter — RoundSmarter LLC Effective: June 10, 2026