Sovereign Data Governance

Privacy Policy & Client Data Sovereignty Charter

Boostara Innovations adheres to the strictest global biomedical privacy standards: HIPAA, GDPR, and the Kenya Data Protection Act 2019.

2. What Information is Collected & How It is Handled

A. Medical Images & Scans:

X-rays, dermoscopy photos, or DICOM files ingested into Boostara X-Ray AI are stored strictly on your local device inside the AES-256 In-App Encrypted Vault. When cloud neural inference is requested, pixels are transmitted via TLS 1.3 into volatile, isolated RAM and deleted/zeroized immediately upon token stream completion. No medical images are saved to server hard drives.

B. Clinical Context & Indications:

Clinical notes, symptoms, and patient demographics entered by the clinician remain inside the local device vault. De-identified clinical parameters used for inference are processed ephemerally in volatile memory.

C. Account Information:

Clinician name, professional email, clinical role, and facility registration are stored securely to manage account authentication, security alerts, and scan token allocations.

D. Payment Information:

For M-Pesa token purchases, transaction reference numbers and phone numbers are verified via authorized payment gateway APIs. Boostara Innovations never sees, collects, or stores M-Pesa PINs or bank card security codes.

E. Device & Diagnostics:

Operating system version, hardware security module availability (e.g. Android Keystore), and non-identifying crash logs to ensure application stability and cryptographic compatibility.

Data Type	Why Collected	Where Processed	Retention Period	User Control & Deletion
Account Information Email, Name, Role	User authentication, session verification, token balance management via Firebase Auth.	Firebase Authentication (TLS 1.3 encrypted in transit).	Duration of active account.	Full Control: Request account & data deletion directly in-app or via support@boostarainnovations.co.ke.
Payment Information M-Pesa Ref, Phone, Play Billing	Verification of token purchases and fraud prevention. Zero PINs or cards stored.	Directly via Safaricom Daraja API / Google Play Billing endpoints.	Retained strictly for statutory tax & transaction reconciliation.	Receipts available in Diagnostic Wallet; transaction history exportable.
Medical Images X-rays, ECGs, Ultrasounds, MRI	Primary clinical diagnostic inference & bounding-box visualization.	Transient Cloud AI RAM: Ingested into ephemeral GPU memory; encrypted at rest on local device.	Zero Server Disk Retention: Zeroized in GPU RAM upon completion. Stored indefinitely on device vault.	Full Control: Delete anytime in In-App Vault; deletes local AES-256 ciphertext and cryptographic keys.
Voice Dictation Microphone Audio	Speech-to-text clinical context transcription for frontline clinicians.	Real-time acoustic streaming over TLS 1.3 to speech transcription engine.	0 Days on Server: Audio stream discarded immediately after text string return.	Microphone permission can be revoked at any time in Android system settings.
Clinical Context Symptoms, Vitals, Notes	Multi-modal clinical correlation and differential diagnosis generation.	Processed alongside image tensors in ephemeral inference session.	Saved locally in encrypted device database; zero permanent server storage.	Editable and deletable per case inside clinical history screen.
Diagnostic Reports PDF, DICOM SR, Text	Clinical decision-support documentation for clinician sign-off.	Compiled on client device; stored in In-App Encrypted Vault.	Client-managed on device storage until erased by user.	Export to PDF/DICOM or permanently erase with one tap.
Device & Security Tokens App Check, Device Binding	API abuse prevention, bot protection, and ensuring only genuine apps connect.	Firebase App Check / Google Play Integrity API.	Rotated dynamically every 60 minutes.	Revoked automatically upon application uninstall or account logout.

Data Type

Why Collected

Where Processed

Retention Period

User Control & Deletion

Account Information
Email, Name, Role

User authentication, session verification, token balance management via Firebase Auth.

Firebase Authentication (TLS 1.3 encrypted in transit).

Duration of active account.

Full Control: Request account & data deletion directly in-app or via support@boostarainnovations.co.ke.

Payment Information
M-Pesa Ref, Phone, Play Billing

Verification of token purchases and fraud prevention. Zero PINs or cards stored.

Directly via Safaricom Daraja API / Google Play Billing endpoints.

Retained strictly for statutory tax & transaction reconciliation.

Receipts available in Diagnostic Wallet; transaction history exportable.

Medical Images
X-rays, ECGs, Ultrasounds, MRI

Primary clinical diagnostic inference & bounding-box visualization.

Transient Cloud AI RAM: Ingested into ephemeral GPU memory; encrypted at rest on local device.

Zero Server Disk Retention: Zeroized in GPU RAM upon completion. Stored indefinitely on device vault.

Full Control: Delete anytime in In-App Vault; deletes local AES-256 ciphertext and cryptographic keys.

Voice Dictation
Microphone Audio

Speech-to-text clinical context transcription for frontline clinicians.

Real-time acoustic streaming over TLS 1.3 to speech transcription engine.

0 Days on Server: Audio stream discarded immediately after text string return.

Microphone permission can be revoked at any time in Android system settings.

Clinical Context
Symptoms, Vitals, Notes

Multi-modal clinical correlation and differential diagnosis generation.

Processed alongside image tensors in ephemeral inference session.

Saved locally in encrypted device database; zero permanent server storage.

Editable and deletable per case inside clinical history screen.

Diagnostic Reports
PDF, DICOM SR, Text

Clinical decision-support documentation for clinician sign-off.

Compiled on client device; stored in In-App Encrypted Vault.

Client-managed on device storage until erased by user.

Export to PDF/DICOM or permanently erase with one tap.

Device & Security Tokens
App Check, Device Binding

API abuse prevention, bot protection, and ensuring only genuine apps connect.

Firebase App Check / Google Play Integrity API.

Rotated dynamically every 60 minutes.

Revoked automatically upon application uninstall or account logout.

3. Data Retention & Zero Server Hoarding

Server Retention: 0 Days. Because we do not hoard patient medical scans on centralized server disks, there is zero persistent database of patient images to be breached or subpoenaed. Patient data lives permanently on the clinician's authenticated physical device until manually deleted or exported by the clinician.

4. Encryption & Access Controls

All data in transit is encrypted using TLS 1.3 with pinned certificates. Data at rest on the client device is sealed with AES-256-GCM using cryptographic master keys derived from the user's hardware biometric authentication via the Argon2id key derivation function. Boostara Innovations holds zero master backdoors.

5. User Rights & Statutory Compliance

In full accordance with the Kenya Data Protection Act 2019, HIPAA Privacy & Security Rules (45 CFR 164), and GDPR Article 9:

Right to Access & Portability: You can export all reports and images as standard DICOM or encrypted PDF at any time.

Right to Erasure: Clearing the app cache or deleting records inside the In-App Vault permanently destroys the local ciphertext and keys.

Right to Object: You can opt out of any non-essential analytics at any time in app settings.

6. Contacting the Data Protection Officer (DPO)

For regulatory inquiries, compliance audits, or hospital institutional review board (IRB) assessments:
Data Protection Officer: Boostara Innovations Legal & Regulatory Directorate
Official Privacy Email: privacy@boostarainnovations.co.ke
General Support: support@boostarainnovations.co.ke