Privacy Policy

1. Introduction

Lumio Ventures, LLC ("Rekupr", "we", "our", or "us") operates the Rekupr medical bill analysis service (the "Service"). This Privacy Policy explains how we collect, use, store, and protect your information when you use our Service.

By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the Service.

Effective date: March 27, 2026.

2. Information We Collect

We collect several categories of information depending on how you interact with the Service.

Documents You Upload

• Medical bills, statements, and invoices
• Explanation of Benefits (EOB) documents
• Insurance-related documents

The contents of these documents may include: patient names, provider and facility names, dates of service, medical procedure codes (CPT, HCPCS, ICD-10), diagnosis codes, financial amounts (billed, allowed, paid, patient responsibility), insurance member and group numbers, account numbers, and other health-related information.

Medical Records You Connect (Optional)

If you choose to connect a hospital or clinic patient portal, we read parts of your medical record from that provider's system through the same patient-access interface the portal uses. You approve the connection on the provider's own sign-in page, which shows you exactly what you are sharing, and you can disconnect at any time from Settings. We read:

• Visits: dates, admission and discharge, and where you were seen
• Procedures, tests and orders, with the codes your provider recorded
• Diagnoses and problems addressed during the visit
• Medications, allergies and immunizations recorded during the visit
• Visit notes and reports your provider attached to the visit
• Insurance coverage on file with the provider

We never write anything to your medical record. We do not read messages between you and your care team, and we do not read records from any provider you have not connected. We use these records for one purpose: checking the bills in your case against what your provider documented. We do not share them with your provider, your insurer or anyone else unless you ask us to include them in an appeal.

Insurance Accounts You Connect (Optional)

If you choose to connect your health insurance account, you authorize us to sign in to your insurer's member website as you and act on your behalf to retrieve your information. The connection is used only to read: we do not use it to change your account, send messages, file claims or make payments. You can disconnect at any time. We retrieve, for up to the last 24 months depending on what your insurer shows:

• Your plan details: insurer, plan name and type, member and group numbers, and effective date
• Coverage and benefit figures, such as your deductible, out-of-pocket maximum, copays and how much of each you have used
• Your claims: dates of service, provider names, billed amounts, what you owe, and the insurer's claim reference
• Explanation of Benefits (EOB) PDFs for those claims
• Your plan's coverage documents, such as a Summary of Benefits and Coverage, when your insurer offers them

Your password and codes: You enter your insurer username and password, and any one-time code your insurer sends you. Your password is used only to sign in and is never stored. A one-time code is used once and then discarded. We keep your username only in masked form (for example "ab****") so you can recognize the connection. So we can update your information later without asking for your password each time, we save the signed-in session your insurer's website gives us, much like staying signed in on a browser. That saved session is encrypted and used only to read your insurer account for you.

How often: We read your insurer account when you connect, about once a week after that while the connection is active, and whenever you ask us to sync. If your insurer ends the saved session, we stop syncing and ask you to sign in again with one in-app notice and one email, which contains a link and no health details.

We use this information for one purpose: checking the bills in your case against what your plan covers and what your insurer processed. We do not read any insurer account you have not connected. We do not sell this information or use it for advertising, and we do not share it with your provider, your insurer or anyone else unless you ask us to include it in an appeal.

Account Information (Registered Users)

• Email address
• Name
• Authentication method (magic link tokens or Google OAuth identifier)

Profile Information (Optional)

• Phone number
• Mailing address
• Date of birth
• Insurance member ID

All optional profile fields are encrypted at rest.

Anonymous Visitor Data

If you use Rekupr without creating an account, we assign a unique visitor identifier to your browser session. We collect the following information, all of which is encrypted at rest:

• IP address and browser user agent
• Basic engagement data: pages visited, documents uploaded, and marketing attribution (UTM parameters, referrer URL)

Chat Conversations

If you use Rekupr's AI assistant, your messages and the assistant's responses are stored and encrypted at rest.

Technical and Usage Data

• Device type, browser information, operating system
• Pages visited and features used
• General geographic location (country level)

Payment Information

Payments are processed by Stripe. We do not store your credit card number, expiration date, or CVC on our servers. We receive a transaction record from Stripe confirming payment.

3. How We Process Your Documents

When you upload a document, we use automated systems to analyze it:

• Your document is transmitted securely and stored with encryption
• AI document extraction on Google Vertex AI, through its US-only endpoint, reads the text and figures from your document
• Automated analysis, including AI, checks for potential billing issues
• If you upload both a bill and an EOB, we compare them for discrepancies
• Findings, potential savings estimates, and suggested actions are generated and stored encrypted in our database

Insurance Account Connections

When you connect an insurance account, an automated browser signs in to your insurer's member website and moves through it for you. An AI model (Google's Gemini, on Google Cloud's Vertex AI through its US-only endpoint) guides the browser. To decide where to click, the model looks at screenshots of your insurer's pages, which can show your health and insurance information. The model never sees your password or one-time codes: the browser types them in without passing them to the model.

• The browser is limited to your insurer's own website and stops if it is sent anywhere else
• We save the navigation steps that worked on each insurer's website so later syncs need less AI help. These steps are shared across members who use the same insurer, and personal and health information is removed from them before they are saved.
• EOBs we retrieve are not analyzed on their own. Each one is held until you upload a bill that may be from the same visit, or you choose to attach it to a bill. We then read and compare it the same way as an EOB you upload yourself.

4. Third-Party Processors

We use the following third-party services to operate Rekupr:

Google Cloud Platform services that process your document content are covered by a HIPAA Business Associate Agreement. Google OAuth is a separate service used only for social login and does not receive any document or health data.

5. How We Use Your Information

• Service delivery: Processing your documents, generating analysis results, and providing bill review insights
• Insurance connections: If you connect an insurance account, we use what we retrieve only to check your bills against your plan and your insurer's records
• Communications: Notifications about analysis results, account updates, and service announcements
• Product improvement: We use only aggregated, anonymized, and de-identified data that cannot identify individuals
• Legal compliance: Responding to lawful requests and enforcing our terms

We do NOT sell your individual data to third parties. We do NOT use your data for advertising or ad targeting. We do NOT share your document contents with other users.

6. Data Storage and Security

We implement multiple layers of security to protect your information:

• Application-level encryption: Over 50 database fields containing sensitive information (names, medical codes, diagnoses, financial identifiers, addresses, phone numbers, insurance IDs) are individually encrypted using AES-256-CBC
• File storage encryption: AES-256 server-side encryption on Google Cloud Storage
• Transport encryption: TLS 1.2 or higher with HTTPS enforced on all connections
• Session encryption: Sessions are encrypted to prevent tampering
• Queue encryption: Background processing jobs use encrypted payloads
• Log protection: A PHI masking processor automatically redacts sensitive data from application logs
• Insurance connections: Your insurer password is never stored, and one-time codes are discarded after use. The saved insurer session and your masked username are encrypted with the same field-level encryption as your health data. The service that signs in to your insurer is internal, accepts only signed requests from our application, and logs only technical step names and outcomes, never your credentials, page content or claim details.

7. Data Retention

• Original uploaded files: Automatically deleted within 3 days of analysis. If a document cannot be analyzed, its original file is deleted within 90 days.
• Analysis results: Kept for as long as you keep them, with no time limit, so you can come back to a report later. When you delete a report, it is permanently erased within 2 days and cannot be restored.
• Deleted files: Our storage provider holds a deleted file in a recovery area for 7 days before it is gone for good. We use this only to recover from accidental loss.
• Connected medical records, raw copy: The copy we receive from your provider's system is deleted 90 days after we receive it, or as soon as you disconnect, whichever comes first.
• Connected medical records, kept for your review: The records that support a finding on a bill, or belong to a visit you confirmed, stay with that case and are deleted when you delete the case, the bills in it, or your account. Records that nothing relies on are deleted 90 days after we receive them.
• Disconnecting a provider: Disconnecting removes our access immediately and stops any further reading. Within the hour we delete the raw copy and every record that no finding or confirmed visit relies on. We ask the provider to cancel our access where their system allows it.
• Insurance connection: The saved insurer session is kept while your connection is active and deleted as soon as you disconnect. An EOB we retrieve stays held in your account, with no fixed time limit, until it is matched to a bill, you disconnect, or you delete your account. Once matched, it follows the same rules as the bill it belongs to.
• Disconnecting an insurer: Disconnecting stops all syncing and removes our ability to sign in straight away. We delete the saved session, your masked username, and every retrieved EOB that is not attached to a bill. EOBs already attached to a bill stay with that bill, and the plan details and coverage documents added to your insurance information stay there, until you delete them or your account. We keep a record of past syncs (dates, counts and outcome, no claim details) until you delete your account. We cannot sign you out of your insurer's website; that session ends on its own.
• Medical record consent: Your record of agreeing to connect a provider is kept for 6 years, as the law requires, even after you disconnect. It records which kinds of records you agreed to share and when, not the contents of your medical record.
• Audit logs: Kept for at least 6 years, as HIPAA requires. They record account and access activity, not the contents of your bills.
• Account deletion: Deleting your account is permanent once you confirm it. Your bills, analyses, appeals, family members, chat history and insurance connections (including saved sessions, retrieved EOBs and sync history) are removed straight away, and the remaining account record and stored files are erased within 48 hours. We keep only an audit record of the deletion (hashed identifiers and counts, never your name, email or health information) for 6 years, and records of consents and agreements you signed, which hold no bill content. Stripe, our payment processor, keeps its own payment records under its own retention policy.
• Anonymous visitor data: Automatically purged 90 days after the last interaction with the Service

Beta Program Data

All documents uploaded during the beta testing period, along with all associated extracted data, will be permanently deleted within 30 days of the beta program's conclusion. This includes line items, diagnosis codes, financial amounts, provider and patient information, detected billing issues, AI-generated summaries and letters, and chat conversations. The deletion is a full cascading purge; no derived or extracted data from your uploaded documents will be retained after this period.

We will notify all beta participants via email when the beta program concludes and the deletion window begins.

Exclusions: Anonymized or aggregated analytics data, audit logs (retained per our standard 6-year compliance retention policy), and your account record itself are not affected by beta data deletion. Your account will remain active unless you request its deletion separately.

8. Your Rights

You have the following rights regarding your personal information:

• Access: Download your data from Account Settings
• Correction: Update your profile information at any time
• Deletion: Permanently delete your account and all associated data from Account Settings
• Disconnect an insurer: Disconnect a connected insurance account at any time from its connection page, which stops all syncing straight away
• Export: Request a portable copy of your data
• Opt out of marketing: One-click unsubscribe in any email, or manage preferences in Account Settings

To exercise any of these rights, visit your Account Settings or contact us at support@rekupr.co.

9. HIPAA and Health Data

Rekupr is not a healthcare provider, health plan, or healthcare clearinghouse. We are not a HIPAA Covered Entity or Business Associate in the traditional sense.

You upload your own documents voluntarily. We receive health information from providers or insurers on your behalf only through the optional connections described in Section 2, where you explicitly authorize us to read your record from your provider's patient portal or your account on your insurer's member website.

Despite not being a Covered Entity, we recognize that the documents you upload may contain Protected Health Information (PHI). We voluntarily apply HIPAA-grade safeguards, including:

• Encryption at rest for all health-related data fields
• A Business Associate Agreement with Google Cloud Platform
• PHI masking in application logs
• Access controls ensuring you can only view your own documents
• Comprehensive audit logging
• Automatic deletion of original uploaded files within 3 days

Health Breach Notification

Because the Service holds health information you supply and, if you connect a provider or an insurer, records from your medical record or insurance account, we treat ourselves as a vendor of personal health records under the Federal Trade Commission's Health Breach Notification Rule (16 CFR Part 318). If we discover that unsecured health information held by the Service has been acquired by someone without your authorization, we will notify you without unreasonable delay and no later than 60 calendar days after we discover it, and we will notify the Federal Trade Commission and, where the rule requires it, prominent media outlets. The notice will say what happened, what information was involved, what we are doing about it, and what you can do.

10. Children's Privacy

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us at support@rekupr.co so we can promptly delete it.

11. Cookies and Tracking

We use the following categories of cookies and tracking technologies:

• Essential cookies (always active): Session cookies required for the Service to function, including maintaining your login state and preventing cross-site request forgery. These cannot be disabled.
• Website analytics cookies (public pages): On our public pages (such as the home page, pricing, blog, and knowledge base), and only when you are not signed in, we load Google Analytics to understand how visitors find and use our website. It collects pages visited, device and browser information, and approximate location. Google Analytics is never loaded once you sign in or on any page where you upload or view a bill, so it never receives health or bill information.
• Product analytics cookies (opt-in only): If you accept analytics cookies via our cookie consent banner, we record how the Service is used: pages visited, general device information, and usage patterns. If you decline, no analytics data is collected.

We do not use advertising cookies or third-party tracking pixels. Apart from Google Analytics on public pages as described above, analytics stay on our own infrastructure. No analytics data is used for ad targeting.

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information.

Your Rights

As a California resident, you have the right to:

• Know what personal information we collect, use, disclose, and sell (if applicable)
• Delete your personal information, subject to certain exceptions
• Correct inaccurate personal information we hold about you
• Opt out of the sale or sharing of your personal information
• Non-discrimination for exercising any of your CCPA rights

What We Do Not Do

• We do not sell your personal information to third parties
• We do not share your personal information for cross-context behavioral advertising
• We do not use sensitive personal information for purposes other than providing the Service

Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

• Identifiers: name, email address, IP address, unique visitor ID
• Commercial information: purchase and transaction records
• Internet or electronic network activity: pages visited, device information, browser type
• Sensitive personal information: health-related data contained in documents you upload (medical codes, diagnosis codes, financial amounts, insurance identifiers). This information is collected only because you voluntarily provide it and is used solely to deliver the Service.
• Insurance and account login information: if you connect an insurance account, your plan details, benefit figures, claims, EOBs and plan documents, a masked form of your insurer username, and an encrypted saved sign-in session. Your insurer password is used to sign in and is never stored. This information is collected only because you choose to connect and is used solely to deliver the Service.

Exercising Your Rights

To exercise any of these rights, you may:

• Use the deletion and export features in your Account Settings
• Email us at support@rekupr.co with the subject line "CCPA Request"

We will verify your identity before processing your request and respond within 45 days as required by law. You may designate an authorized agent to make a request on your behalf.

13. Changes to This Policy and Contact

We may update this Privacy Policy from time to time. When we do, we will post the updated policy on this page and change the "Last updated" date at the top. For material changes, we will send an email notification to registered users.

If you have questions about this Privacy Policy, want to exercise your data rights, or have concerns about how your information is handled, please contact us:

Lumio Ventures, LLC
Email: support@rekupr.co