Privacy

This page is a draft, pending legal review. It is not legal advice. The clinic owns its records. Right now your records are saved on this device only. Export regularly. Holdra does not keep a copy. Improvement uses de-identified data (Fla. Stat. 474.2165(4)(c)). Holdra does not sell identifiable data.

Holdra collects the minimum the log and the product need: the drug line, the people who sign it, and the clinic registration. It does not collect a client phone, email, or payment card inside the drug book. Owner names and addresses on a dose line are part of the clinic's record. They are excluded from analytics. There is no PII telemetry.

Records stay on the clinic computer. Clearing the browser's data or losing the computer loses the book.

Identifiable records in the book belong to the clinic. Improvement uses de-identified data. A published benchmark cell needs at least 10 clinics, and no single clinic may be more than half of that cell. Clinics can opt out of benchmarks. No cell is published until the threshold is met.

Support cannot open this book. There is no copy on a server. A government or legal request to the vendor needs legal process. Holdra notifies the clinic unless the law bars notice. Holdra does not voluntarily share identifiable data with an agency or a buyer.

If a breach of personal information occurs, Holdra follows Fla. Stat. 501.171, including notice within 30 days where that statute applies. Material privacy changes get 30 days' notice and an opt-in before any new use. Old data is not relabeled for a new use.

After cancellation, export PDF and JSON from the clinic computer. Holdra does not keep a retention copy. The clinic keeps its own export so it can meet its retention duty.

PINs are stored as hashes. The sample walkthrough still lists three sample PINs on the sign-in sheet so a reviewer can switch users. Those digits are not a production secret.