Privacy Policy

At a glance

We never sell personal information or use it for advertising.
Our apps contain no advertising, analytics, or tracking software.
Health information is never stored on a responder's phone.
Every time a record is viewed, we log who viewed it and when.
Face recognition is off unless your organization turns it on, and even then only for people who enroll and consent in writing.
Data is stored in the United States and encrypted in transit and at rest.

Who we are and what this policy covers

Minutes Matter, LLC (“Minutes Matter,” “we,” “us”) is a Tennessee company. We provide a service that lets credentialed first responders see a person’s emergency-relevant health information by scanning a QR credential or, where enabled, by face identification.

This policy covers the Minutes Matter apps for iPhone and Android, the web portals at api.minutesmatterapp.com, and this website.

We provide the service to organizations such as schools, universities, employers’ occupational-health programs, and event medical providers. We hold health records on behalf of those organizations. For health information protected by HIPAA we act as the organization’s business associate, and for student education records protected by FERPA we act as a school official under the school’s direct control. Your organization’s own privacy notices also apply to your information, and your organization decides who in it can access the service.

What we collect

Emergency records of enrolled people

Your organization provides this information, usually by importing it from its student or personnel systems, and you may add to or correct it yourself in the personal portal:

Name, date of birth, phone number, home address, and your school, campus, or work site
Emergency contacts
Blood type, allergies and their severity, medications and dosages, medical conditions, past surgeries, and immunizations
Health documents such as care plans and emergency action plans
Notes that responders record about incidents and the care given
The identifier encoded in your QR credential

Face data, only if enabled

Only if your organization has enabled face identification and you choose to enroll and consent in writing, we create a face template from a photo you provide. See Face recognition below.

Accounts for responders and administrators

For people who sign in to the apps or the administration portal, we keep an email address, role, organization, and sign-in history. Accounts are created by your organization’s administrator, or you may sign in through your organization’s own sign-on system.

Access and audit records

We record every time a record is opened, every QR or face scan, and every sign-in and sign-out, along with the account, time, and whether it happened on iPhone, Android, or the web. If someone takes a screenshot while signed in to the app, we record that it happened. We never capture the screenshot itself.

Camera use

The apps use the camera to read QR credentials. The code is decoded on the phone; camera images are not stored or sent to us. For face identification, a single photo is sent to our servers to search for a match. That photo is not saved.

Technical information

Our servers keep standard logs, including IP address, request time, and browser or device type, for security and troubleshooting. The web portals use cookies only to keep you signed in. The Android app uses Google’s ML Kit to read QR codes on the device; Google may receive anonymous performance and usage statistics about that component, but not camera images or your information.

This website

This website uses no advertising or analytics cookies. The demo request form opens your own email app and sends nothing to us until you choose to send the email. Our website host adds a script that measures page performance.

How we use information

To show an enrolled person’s emergency information to authorized responders at the point of care
To sign people in, enforce each organization’s access rules, and keep the audit trail
To protect the service against misuse and investigate security problems
To show plain-language drug information and interaction warnings, using medication names only
To provide support to organizations and the people they serve
To meet our legal obligations and our agreements with organizations

We do not use health information for marketing, advertising, or profiling, and we do not use it to train machine-learning models.

Responders. A credentialed responder can view the record of any enrolled person whose credential they scan, including someone enrolled by a different organization. This is deliberate: a medic must be able to help a visitor from another school or site. Every view is logged.
Your organization’s administrators. They can see names and enrollment status to manage accounts. They cannot see medical information.
You. You can see and update your own record in the personal portal.
Our service providers. Amazon Web Services hosts our servers and database, runs sign-in, and performs face matching, under a HIPAA Business Associate Addendum. The U.S. Food and Drug Administration’s openFDA service receives medication names, with no information about who takes them, to return drug information.
When the law requires it. We disclose information when required by law, subpoena, or court order, and we tell the affected organization unless we are legally prohibited from doing so.
If our business changes hands. Information may transfer to a successor that agrees to protect it under terms at least as strict as these, and we will notify organizations first.

We do not sell personal information and do not share it for cross-context behavioral advertising.

Face recognition and biometric data

This section is our written policy for biometric data, including its retention schedule and destruction guidelines.

Off by default, then opt-in. Face identification is off for every organization until its administrator turns it on. Even then, no face data exists for a person unless they choose to enroll in the personal portal. Everyone else is identified by QR credential.
Written consent first. Before any face data is created, the person reads a disclosure of what is collected, why, and how long it is kept, and gives written consent. They must also confirm that they are 18 or older, or that a parent or legal guardian has authorized enrollment.
What we keep. Amazon Rekognition converts the enrollment photo into a mathematical face template. We do not keep the photo. We store only a reference to the template.
Single purpose. Face data is used only to identify an enrolled person to authorized responders. We never sell, lease, trade, or otherwise profit from it, and we disclose it only to our service provider for this purpose or when the law requires.

We permanently destroy a person’s face template at the earliest of these points:

Immediately when the person selects “Remove Biometrics” in the personal portal or withdraws consent
When the person’s record is deleted
Immediately when the organization turns face identification off
Within 30 days after the organization’s agreement with us ends
Three years after the person’s last interaction with the service

Children and students

Our apps are used by adult responders and are not directed to children. Records about students, including children under 13, are provided by their school for health and safety purposes, and the school authorizes that collection on behalf of parents. We use those records only to provide the service to the school. Parents and guardians can review, correct, or request deletion of their child’s information through the school or by contacting us.

Security and where data is stored

All data is stored in the United States on Amazon Web Services. Connections use TLS 1.2 or later, and stored data and backups are encrypted with AES-256. Each organization’s records are separated from every other organization’s by the database itself. The apps never store health information on the phone and require signing in every time they open. Every record view is logged on our servers.

No system is perfectly secure. If a breach affects your information, we will notify your organization promptly and support the notifications the law requires.

How long we keep information

Information	How long
Emergency records	While the organization uses the service. Deleted within 30 days after the record is removed or the organization’s agreement ends.
Face templates	According to the schedule in Face recognition.
Responder and administrator accounts	Until the account is closed. Deleted within 30 days of a verified request.
Access and audit records	For the life of the organization’s account, and afterward without health details where the law requires us to show who accessed a record.
Backups	Overwritten automatically within 7 days.
Server logs	A limited period for security and troubleshooting.

Your choices and rights

See and correct your record at any time in the personal portal, using the account your organization provided.
Remove your face data at any time in the portal, which also withdraws your consent.
Ask us to delete your account or record using the steps on our data deletion page. Uninstalling the app does not delete anything.
Health and education record rights. Rights under HIPAA and FERPA, such as access and amendment, are exercised through your organization. We help your organization respond.

Depending on where you live, you may have additional rights, such as to know what we hold about you, to correct it, to delete it, or to receive a copy. Contact us to use them. We will not treat you differently for doing so, and we may need to verify your identity first.

Changes to this policy

If we change this policy, we will post the new version here with a new effective date. If a change materially affects how we handle information we already hold, we will notify the organizations we serve before it takes effect.

Contact us

Questions, requests, and privacy concerns: sales@minutesmatterapp.com.

Minutes Matter, LLC · Tennessee, United States