Legal
How we protect your health information
Valdura Health
Version 3.12. Effective October 26, 2026.
This page describes how health information about you may be used and shared, and how you can get access to it. Valdura is not a HIPAA covered entity, and this page is not a HIPAA Notice of Privacy Practices. We follow the practices it describes by choice.
About this notice
Valdura Health (a limited liability company, "Valdura," "we," "us," or "our") operates the Valdura health platform: an AI health assistant that explains your bloodwork and health data in plain language, bloodwork you can buy separately, partner-routed product recommendations, a member community, and, where we offer them, a place to keep your Avellum orders and records alongside your own and screens on which you can buy a treatment from our affiliated company Crystal Clear RX, LLC. This notice explains how we may use and share health information that identifies you, and the rights you have over that information.
Who is responsible for your health information, and our HIPAA status. Valdura Health LLC operates the Valdura platform and brand. Valdura is a direct-to-consumer, cash-pay service that does not bill health insurance or submit healthcare claims to a health plan, which is the activity that brings a provider under HIPAA. For that reason Valdura is not a HIPAA covered entity and is not legally required to issue a HIPAA Notice of Privacy Practices, and this page is not one. We publish it, and follow the practices it describes, by choice, because we protect your health information with safeguards modeled on HIPAA. Valdura Health LLC and Avellum Health Co LLC are affiliated companies under common ownership, and so are Avellum Health, LLC, Crystal Clear RX, LLC and Precision Pharma Corp. Avellum Health Co LLC is the shared-services company for Valdura and its affiliated companies: it runs payroll for the staff who work across those companies, holds the vendor accounts they share, and holds the Business Associate Agreements with those vendors. Under a written business associate and data protection agreement, Valdura relies on Avellum Health Co LLC's privacy and security program. The Business Associate Agreements that cover the vendors handling your health information are held by Avellum Health Co LLC, except the one for our company email, which Valdura holds with Google. The affiliated company that packs and ships your collection kit is bound by the same written business associate and data protection agreement. Your enforceable rights over your health information come from consumer health-data laws, principally the Washington My Health My Data Act and CCPA/CPRA. When this notice refers to what "we" or "Valdura" do with your health information, it refers to Valdura operating under this program.
We provide this notice in the spirit of the federal privacy regulations issued under the Health Insurance Portability and Accountability Act (HIPAA), at 45 CFR 164.520, even though we are not a covered entity, and in keeping with the consumer health-data laws that do apply to us, including the Washington My Health My Data Act. Our Consumer Health Data Privacy Policy gives the disclosures those laws require, including the affiliated companies we share consumer health data with by name.
In this notice, "health information" and "protected health information" (PHI) mean information that identifies you (or could reasonably be used to identify you) and relates to your health, your care, or payment for your care. This includes your bloodwork and biomarker results, the health history and goals you share, what you log day to day (meals, water, weight, workouts, supplements and medications, symptoms, and your daily check-in), the cycle, fertility, pregnancy, and sexual-activity information you record, the health data held by any wearable, health app, or phone health store you connect, your conversations with the AI assistant, documents and photos you upload, the messages you send our support team and the transcript of any voicemail you leave on our support line, the questions you send to a live session or webinar, the answers you give to the medical questions for a treatment you request from Crystal Clear, the medical intake answers, orders and visit status Avellum sends us when your accounts are connected, the medication and dates of a protocol program you bought, and the account details that tie this information to you. Reproductive and sexual health information is part of this. The Washington My Health My Data Act and California law treat it as its own protected category, and so do we: it carries every right and safeguard in this notice.
This notice applies to adults 18 and older. The Valdura platform is not intended for anyone under 18, and it is not for medical emergencies. If you are experiencing an emergency, call 911 or your local emergency number.
Information you choose to publish
The Service includes a member community. If you publish a post there, the text you wrote and the display name you chose become visible to every Valdura member, including members on a free account. That disclosure is your own act: you decide what to write, whether to publish it, and whether to take it down, and we never publish anything in the community on your behalf or place you in it by default.
Nothing else about you goes with a post. Your legal name, your contact details, your lab results, your health history, the data from any device, health app, or phone health store you connect, your cycle and other reproductive information, what you write to our support team, your uploaded documents and your conversations with the assistant are not shared with other members, and your display name is a name you choose for this purpose rather than the legal name you gave us for lab orders.
Taking a post down removes it from the community for everyone, but it cannot unread it for anyone who already saw it. Posts are screened before they publish, a post may be refused or removed, other members can report a post, and you can hide another member's posts from your own view.
The same holds for the spaces you choose to join. A post you publish inside a circle a practice runs in Valdura, or on a season's team, is shown only to that space's members and, for a circle, the practice. Joining a season or a circle is your own choice, and we place you on a team only inside a season you chose to join. A season shares nothing from your health record with your team: teammates see only a coarse weekly team level, never your own points or the days you took part, and a circle's practice sees only counts unless you separately let it see your name.
Accounts connected to Avellum
If you are a patient of our affiliated company Avellum Health, LLC, you can ask Avellum, by signing an authorization on Avellum, to keep your health information in Valdura. Avellum then asks us to connect your Valdura account, or to open a free one for you, using your confirmed email address, your name, your language, Avellum's own reference for you and a reference to the authorization you signed. From then on, Avellum sends us your Avellum orders, where your visits stand, and the answers you give on Avellum's medical intake once you sign it. Once we receive this information, we protect it as this notice describes.
- Orders and visits. We keep the last copy Avellum sends so we can show it to you, and delete it when the accounts are disconnected. The assistant can read it to answer your questions about your orders.
- Medical intake answers. Your sex at birth, height and weight, and the conditions, surgeries, medications, allergies and goals you reported, each with its question as you saw it and the date you signed. Avellum never sends us your answers about mental health, suicidal thoughts, eating disorders, substance use, pregnancy, HIV, blood pressure or heart rate, the result you saw or its reasons, photos or documents, notes or decisions from your care team, your dose or prescription details, your date of birth, address, phone number or state, or your payment card. You can read them, read-only, on the page "From your Avellum medical intake", and delete one intake or all of them. The assistant can read them to help you unless you turn off "Let the assistant read these" on that page. We never use them for marketing and do not share them with our partners or any other company, apart from the vendors that run our service for us.
- Answers you choose to send to Avellum. When you start a medical request on Avellum from Valdura, you can choose to send it your sex at birth, your height, a recent weight you entered, the medication and medication allergy lines you keep and the treatment you chose, each shown to you first, so you do not have to type them again. Avellum and the licensed clinicians at its care partner use them only for that request. This disclosure is your own choice, and it appears in your own privacy log.
- Signing in. Where we offer it, on the web, a one-time code lets you go between Avellum and Valdura without signing in again; it tells the other company which account is signing in and nothing from your health record. Signing out of one does not sign you out of the other.
- Stopping. You can disconnect in Settings on the Valdura website, stop sharing in your Avellum account settings, or write to privacy@valdura.health. Sharing stops from then on, and we delete the copy of your Avellum orders and every Avellum medical intake answer we hold. Your Valdura account stays open until you close it.
Our Privacy Policy describes each of these in full under "Accounts connected to Avellum".
Treatments you buy from Crystal Clear in Valdura
Where we offer it, you can buy a treatment from our affiliated company Crystal Clear RX, LLC without leaving Valdura. Crystal Clear is the seller, and a licensed clinician at a medical group affiliated with its telehealth partner, OpenLoop Health, decides whether the treatment is right for you. Valdura does not make that decision.
- What we collect. Your answers to that medical group's questions for the treatments you chose, which can cover conditions such as cancer, kidney and liver disease and heart history, eating disorders, mental health including thoughts of suicide, substance use, pregnancy and breastfeeding, the medicines you take and your allergies, together with the state you are in, the consents you sign and the name you type to sign them.
- What we disclose, and to whom. When you sign and submit your request, we send Crystal Clear your answers, the consents you signed, the state you are in, and your legal name, date of birth, sex at birth, email address, phone number and shipping address, and Crystal Clear passes them, through OpenLoop Health, to the medical group so that its clinician can decide on your request. Nothing of your answers is sent for a request you have not signed. This disclosure appears in your own privacy log and in any accounting of disclosures you request.
- How we use them. Only for that request: to send it, to show your answers back to you, and, if an answer means a treatment may not be safe for you right now, to stop the request and, for a time, stop offering you these treatments in Valdura. Our AI assistant never reads them, and we never use them for marketing.
- Protocol programs. If you buy a protocol membership from Crystal Clear, Crystal Clear tells us the medication's name and the dates you paid for, so we can open that medication's program for you. It never sends us your dose, who prescribed it, or your answers to medical questions.
- How long we keep them. For as long as your account is open, and they are deleted with your account. Crystal Clear and the medical group keep their own records of your request under their own privacy commitments and the health privacy rules that bind them.
Our Privacy Policy describes each of these in full under "Treatments you buy from Crystal Clear in Valdura".
Your rights regarding your health information
You have the following rights over the health information we hold about you. To exercise any of them, contact our Privacy Officer at privacy@valdura.health. We will respond within the timeframes the law requires.
The right to inspect and copy
You have the right to inspect and obtain a copy of the health information we hold about you, including an electronic copy when we hold it electronically (which is how we hold most of your information). You can ask us to send your copy to you or to another person you name in writing. In the limited cases where the law allows us to deny a request, we will tell you in writing and explain any right you have to have the denial reviewed.
The right to request an amendment
If you believe information we hold about you is incorrect or incomplete, you have the right to ask us to amend or correct it. Please make your request in writing and tell us why. We may deny a request in the limited circumstances the law allows, for example where we did not create the information or where it is already accurate and complete. If we deny your request, we will explain why in writing and tell you how to respond.
The right to an accounting of disclosures
You have the right to request an accounting of certain disclosures we have made of your health information. This is a list of disclosures other than those made for treatment, payment, health care operations, disclosures you authorized, and certain other categories the law excludes. We maintain audit logging of access to your health information, which supports our ability to provide this accounting.
The right to request restrictions
You have the right to request that we restrict how we use or disclose your health information for treatment, payment, or health care operations. We are not required to agree to every request, but where we do agree, we will honor the restriction except in an emergency.
The right to request confidential communications
You have the right to ask that we communicate with you about your health information in a particular way or at a particular place, for example by a specific email address. We will accommodate reasonable requests.
The right to a paper or electronic copy of this notice
You have the right to a paper or electronic copy of this notice at any time, even if you agreed to receive it electronically. You can request one at privacy@valdura.health, and the current version is available at www.valdura.health.
The right to be notified of a breach
You have the right to be notified if there is a breach of your unsecured health information.
Additional consumer health-data rights
Depending on where you live, consumer health-data and privacy laws may give you further rights, and we extend these rights to our members:
- Deletion. You may ask us to delete your health information, or delete your account yourself in Settings. Your account closes right away, and your account and the health information in it are permanently deleted within 31 days of your request; our encrypted backups are overwritten within 35 days after that. We ask the vendors and affiliated companies that hold copies of what you sent us to delete them, consistent with the Washington My Health My Data Act and similar consumer health-data laws. Some records are kept: our payment processor's payment records and our own billing records of your invoices and subscriptions, which are financial records; a pharmacy's prescription records, which Florida law requires the pharmacy to keep; the test records of the laboratory that ran your sample, which federal laboratory rules require it to keep; the consent to testing and the authorization you signed for each collection kit, with the details recorded when you signed (your name, date of birth, state, kit code, the date and time, and the network address or device you used), which our lab partner's agreement requires us to keep for ten years after your last kit order; the records Crystal Clear and the medical group keep of a treatment request you made, under their own policies and the laws that apply to them; and a de-identified audit trail, which does not identify you. If you remain a member of one of our affiliated companies, such as Crystal Clear RX, LLC, that company keeps its own records and may send us your name and email address again to keep the Valdura access that comes with your membership there, unless you ask it to stop.
- Correction. You may ask us to correct inaccurate health information about you.
- Withdrawing an authorization. You may withdraw any authorization you have given, at any time.
- Opting out of marketing. You may opt out of marketing communications at any time.
- Data portability and export. You may request a copy of your data in a portable, exportable form.
- The list of who received it. You may ask for the list of the third parties and affiliated companies we have shared your health information with, with a way to contact each one.
To exercise any of these rights, contact privacy@valdura.health. We respond within 45 days, and you can appeal a decision, as our Consumer Health Data Privacy Policy describes.
Our commitments
We commit to the following, and applicable consumer health-data laws require much of it:
- Maintain the privacy and security of your health information.
- Give you this notice describing our privacy practices regarding your health information.
- Follow the terms of the notice that is currently in effect.
- Notify you, as required by law, if a breach occurs that compromises the privacy or security of your unsecured health information.
To meet these commitments, we have put specific safeguards in place, including:
- Encryption of your information in transit (TLS) and at rest (database encryption).
- Field-level encryption of the access tokens for any device you connect (AES-256-GCM) and hashing of session tokens.
- Role-based access control, with audit logging of every read and write of your health information.
- An AI assistant that gives general information and makes no clinical decisions, with a clinician involved only where a feature explicitly says so.
- Written agreements with our vendors. The agreements covering our production data vendors are in place: a Business Associate Agreement with each infrastructure vendor (Vercel, Neon, Paubox), with our AI provider (Anthropic), and with our support phone vendor (Quo), each held by Avellum Health Co LLC; a Business Associate Agreement with Google for our company email (Google Workspace), held by Valdura; and, for the pharmacy that ships your collection kit (Precision Pharma), the written business associate and data protection agreement described above.
- A scheduled job that permanently purges a deleted account, and the health information in it, within 31 days of the request, with our encrypted backups overwritten within 35 days after that.
We do not sell your personal or health information, and we do not use third-party advertising or third-party analytics trackers.
Changes to this notice
We may change this notice. We reserve the right to make the revised notice effective for health information we already have as well as for information we receive in the future. When we make a material change, we will post the updated notice at www.valdura.health and update the effective date below. You may request the current version at any time.
How to file a complaint
If you believe your privacy rights have been violated, you may file a complaint with us, and you may also have the right to complain to a government regulator. We will not retaliate against you, and your membership and access to the service will not be affected, for filing a complaint.
- With us: contact our Privacy Officer at privacy@valdura.health. You can also reach our security team at security@valdura.health, or general support at support@valdura.health.
- With a state regulator: consumer health-data laws such as the Washington My Health My Data Act and the CCPA/CPRA are enforced by state attorneys general, and you may file a complaint with the attorney general in your state.
- With the U.S. Department of Health and Human Services: to the extent HIPAA applies to your information, you may file a written complaint with the Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, DC 20201. You can also call 1-877-696-6775 or file online at www.hhs.gov/ocr/privacy/hipaa/complaints.
Privacy Officer and contact information
Our Privacy Officer is responsible for this notice and for handling your privacy questions, requests, and complaints.
- Privacy Officer and data-rights requests: privacy@valdura.health
- Security and incident reports: security@valdura.health
- General support: support@valdura.health
- Website: www.valdura.health
- Mailing address: Valdura Health LLC, 2750 Taylor Avenue, STE A84, Orlando, FL 32806
Effective date: Effective October 26, 2026.
Version 3.12.