1. Who We Are

Listen MD AI ("ListenMD", "we", "us", "our") is an Ontario-incorporated company that provides an AI-powered medical transcription and clinical note generation platform to healthcare organizations across Canada. Our registered address and privacy inquiries contact: contact@listenmd.ai.

2. Scope

This policy applies to:

• Healthcare organizations ("Organizations") that subscribe to ListenMD
• Clinicians, staff, and administrators who use ListenMD on behalf of an Organization
• Patients whose encounters are documented using ListenMD

This policy does not apply to third-party services linked from our platform.

3. Applicable Law

ListenMD operates in compliance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA)
• The Personal Health Information Protection Act (PHIPA) (Ontario)
• Applicable provincial health privacy legislation across Canada

Healthcare Organizations using ListenMD are Health Information Custodians under PHIPA. ListenMD acts as an agent of those custodians in handling personal health information (PHI) on their behalf.

4. What Information We Collect

4.1. Patient Information

We process the following PHI solely to provide transcription and note generation services:

• Patient name and date of birth (entered by clinicians)
• Provincial health number (where provided for EMR linking)
• Audio of clinical encounters (see Section 5 — audio is never stored)
• Real-time transcripts generated from audio
• Structured clinical notes (SOAP, discharge summaries, etc.)

4.2. Clinician and Staff Information

• Name, email address, role
• Authentication credentials (passwords stored as encrypted hashes)
• Session and activity logs (for security and audit purposes)

4.3. Organization Information

• Organization name and administrative contact
• EMR integration credentials (encrypted at rest)

4.4. Technical Information

• IP addresses and device fingerprints (for fraud and unauthorized access detection)
• Browser and OS type
• Session timing and activity logs

5. How We Handle Audio

Audio is never written to disk or stored. When a clinician begins recording, audio is streamed in real time from the clinician's browser to our speech-to-text service (Microsoft Azure Speech, hosted in Canada - see Section 8). The audio stream is processed in memory and discarded immediately. We do not retain any audio recordings.

6. How We Handle Transcripts

Transcripts are generated in real time from the audio stream and stored temporarily to support clinical note generation. Once a clinical note has been successfully generated, the raw transcript is purged from our systems. Transcripts are never used for any purpose other than generating the associated clinical note.

7. How We Use Information

We use the information described above exclusively to:

• Provide transcription and clinical note generation services
• Display generated notes to authorized clinicians for review
• Transmit notes to connected EMR systems at the direction of the Organization
• Maintain security, detect fraud, and enforce our terms of service
• Comply with legal obligations

We do not use patient information for advertising, profiling, model training, or any purpose beyond the services described above.

8. Third-Party Processors

ListenMD uses the following sub-processors to deliver the service:

All sub-processors are bound by data processing agreements. All PHI remains within Canadian data centres.

9. Data Retention

Organizations may request earlier deletion subject to applicable legal retention requirements.

10. Security

ListenMD implements the following safeguards:

• All data encrypted in transit (TLS 1.2+) and at rest (AES-256)
• EMR credentials encrypted using application-level encryption before storage
• Two-factor authentication (2FA) available for all users; enforceable by Organization administrators
• Role-based access controls (clinicians, staff, administrators)
• Audit logging of all access to patient health information
• Automatic session timeouts after inactivity
• New device detection and alerting

11. Patient Consent

ListenMD requires clinicians to confirm that patient consent has been obtained before any recording begins. The platform records the timestamp of that confirmation for each encounter. Obtaining and documenting informed patient consent remains the responsibility of the Healthcare Organization and the treating clinician.

12. Individual Rights

Patients who wish to access, correct, or request deletion of their health information held by ListenMD should contact their Healthcare Organization (the Health Information Custodian). ListenMD will cooperate with custodians to fulfill such requests within the timeframes required by PHIPA.

13. Organizational Responsibilities

Healthcare Organizations subscribing to ListenMD are responsible for:

• Obtaining valid patient consent before using the platform
• Ensuring only authorized personnel access the platform
• Configuring and enforcing appropriate access controls
• Notifying ListenMD promptly of any suspected security incidents
• Complying with PHIPA and all applicable privacy legislation in their jurisdiction

14. Breach Notification

In the event of a privacy breach involving PHI, ListenMD will notify the affected Healthcare Organization without undue delay. The Organization, as Health Information Custodian, is responsible for notifying affected individuals and the Information and Privacy Commissioner of Ontario (IPC) where required by PHIPA.

15. Changes to This Policy

We will notify Organizations of material changes to this policy by email at least 30 days before they take effect. Continued use of the platform after that date constitutes acceptance of the updated policy. The current version is always available at https://listenmd.ai/privacy.

16. Contact

For privacy questions, concerns, or requests:

Listen MD AI — Privacy Officer

contact@listenmd.ai

We will respond to all privacy inquiries within 10 business days.