This policy applies to healthcare professionals and clinical use of ApneaCam.
ApneaCam – Privacy Policy (Clinical Use)
Effective Date: 05/01/2026
Last updated: 10/27/2026
1. Scope
This policy applies to healthcare professionals and clinical organizations using ApneaCam for clinical screening. Where ApneaCam is used for research or clinical validation, the applicable research-specific requirements, agreements and permissions also apply.
2. Information Processed
ApneaCam processes:
- Facial and oral images (frontal, profile, open mouth)
- Selected clinical inputs (e.g., symptoms, demographic information)
- Image-derived attributes and anatomical features relevant to screening
- Image-derived estimates and anatomical measurements
- Screening results and OSA-related risk information
- Optional demographic information, including self-reported racial or ethnic origin, where collected
ApneaCam does not require direct patient identifiers, such as patient name or address, for its standard screening workflow.
The platform processes information that may constitute personal data, even in the absence of direct identifiers.
The identification status of processed data depends on the information involved and the applicable technical and organizational safeguards.
3. Data Roles
Healthcare providers and clinical organizations are responsible for determining and fulfilling their applicable responsibilities regarding patient information, including patient consent or other required authorization and clinical records.
The respective data-protection roles of healthcare providers, Consusis and any relevant partners depend on the processing activities, purposes and applicable agreements. These roles are established through the applicable contractual and data-processing arrangements.
Where Consusis acts as a processor, it processes personal data on behalf of the relevant controller and in accordance with applicable instructions and agreements. Processing for other purposes is subject to the applicable legal basis, permissions and requirements.
4. Use of Data
Processed data is used to:
- generate screening outputs
- support validation and performance analysis
- improve system accuracy
Research, validation, performance evaluation, calibration and product development activities involving patient data are conducted only where the applicable permissions, lawful basis and legal requirements have been satisfied.
5. Research and Validation
ApneaCam may support research, clinical validation, performance evaluation, model calibration and development of sleep apnea screening technologies, subject to applicable legal, ethical, institutional and contractual requirements.
For research use within the usual clinical patient workflow, the healthcare professional must inform the patient about the relevant research-related data use and obtain and document the patient’s agreement through the clinic’s standard patient-intake or consent workflow, where this is the applicable and sufficient authorization mechanism.
Such research use may include self-reported racial or ethnic origin, where collected, for population-level performance evaluation, model calibration and assessment of potential bias.
For specific research studies, patient consent or authorization, ethics review, institutional approval and other requirements must be addressed as applicable to the study, including under the separate study agreement and study-specific consent documentation.
Research data may be de-identified or pseudonymized where appropriate. De-identification does not necessarily mean that information is anonymous.
6. Access to Information
Access to information is limited to authorized personnel, contractors, and collaborators who require access to support platform operation, research, validation activities, security, or product development and who are subject to appropriate confidentiality obligations.
Access to or sharing of information with research collaborators is limited to activities for which the applicable permissions, lawful basis and contractual or other required arrangements are in place.
7. Third-Party Processing
Consusis may use trusted third-party service providers and cloud infrastructure providers to support storage, processing, analytics, and operation of the platform.
Third-party service providers process information on behalf of Consusis where acting in that capacity, under applicable contractual and security requirements. Other recipients, where applicable, may process information in accordance with their respective roles and the applicable privacy disclosures.
8. Data Retention
Information (screening images and session information, screening results and associated records, research and validation datasets) is retained only for as long as reasonably necessary to support system operation, research, validation, regulatory, product improvement, and compliance with applicable legal obligations. De-identified information may be retained for longer periods for scientific, analytical, and algorithm development purposes.
9. Compliance Responsibilities
Healthcare providers are responsible for:
- obtaining appropriate patient consent
- complying with applicable laws, regulations, and institutional policies
- determining appropriate clinical use
Consusis and other relevant parties remain responsible for their respective obligations under applicable data-protection, contractual and other legal requirements.
10. Security
Reasonable safeguards are applied to protect processed data.
11. Virginia Rights
If applicable, individuals may have rights under Virginia law, including access, correction, or deletion of personal data, subject to legal limitations.
12. Contact
For questions or requests, please contact us:
Consusis Inc., 251 Little Falls Drive, Wilmington, DE 19808