Privacy Policy

Introduction

Drug Infusion (the "App") is an educational simulator that helps healthcare students, trainees, and professionals practice intravenous (IV) medication calculations. The App is published by iAnesthesia LLC ("we," "us," "our," or the "Developer"), a Washington State limited liability company located at 100 N Howard St, Ste R, Spokane, WA 99201-0508, United States.

We built Drug Infusion to be private by design. The App has no user accounts, runs no servers that collect your data, contains no third-party analytics or advertising SDKs, and performs no cross-app or cross-site tracking. Substantially all data you create stays on your device.

This Privacy Policy explains, in plain language, what limited data the App involves, how it is used, the narrow circumstances in which Apple (not us) processes data on your behalf, the limited processing connected to our website and support email, and the rights you have under U.S. state privacy laws (including California's CCPA as amended by the CPRA), the EU/UK GDPR, and other applicable laws.

This policy applies to the Drug Infusion application distributed through the Apple App Store and to our related website at druginfusion.com.

Privacy at a Glance

1. Scope and Roles

Who controls what. Because the App is local-first and account-free:

• Data you create on your device (calculations, practice progress, scenarios, simulated infusions, the on-device Activity Log, settings) is stored on your device and under your control. We do not have access to it and do not receive copies of it.
• The limited personal data we actually process is essentially: (a) your purchase entitlement status, which the App checks with Apple on your device and which is not sent to us (we receive only Apple's aggregate sales, download, and analytics reports, which contain nothing about an individual); (b) the contents of any support message you choose to send us; and (c) standard website-visitor data generated when you visit druginfusion.com (see §2.6). For that limited processing, iAnesthesia LLC is the data controller (GDPR) / business (CCPA/CPRA).
• Apple Inc. acts as the payment processor and (if you enable iCloud) as the sync/storage provider, processing certain data on your behalf under Apple's own privacy policy.

This policy covers (a), (b), and (c) and explains (for transparency) the on-device data and the Apple-mediated data, even where we are not the controller of it.

2. Information the App Involves

2.1 Data Stored Locally on Your Device

The following is stored on your device (and in your own device backups, if you make them) and protected by iOS device security. It is not transmitted to us.

• Practice & learning data — drug calculations (generic drug names, concentrations, dose rates, volumes, results), quiz/practice progress and mastery levels, and custom practice scenarios you create.
• Educational infusion-monitoring data (simulation only) — simulated infusion name, rate, volume, start time, duration, rate-change history, and status. Optional free-text room/bed labels are for workflow organization and must not contain patient identifiers.
• App preferences & settings — display precision, warnings, theme, shift times.
• Local usage counters — e.g., the count of free two-person-verification initiations used (to enforce the free-tier allowance) and related entitlement counters (a copy of the free-verification count also syncs through your own iCloud; see §2.3).

2.2 On-Device Activity Log and Pseudonymous Device Identifier

To support the App's educational record-keeping (for example, the verifier's record of a two-person verification outcome), the App maintains a local, on-device Activity Log in a dedicated on-device store, separate from your other app data. Its entries may include practice details such as the generic drug name, the computed rate, and the verification outcome. The Activity Log contains no patient identifiers and is never uploaded by the App.

Each Activity Log entry is tagged with a locally stored pseudonymous device identifier used to distinguish this device in local audit entries. On iOS, this identifier is derived from Apple's vendor-scoped device identifier where available, with a locally generated fallback if the system value is unavailable. It is not your name, email, Apple ID, advertising identifier, or hardware serial number, is not linked by us to your real-world identity, and is not transmitted to us by the App. If you share a practice record (PDF), its author field carries this identifier (or the vendor-scoped value it is derived from). If you share your Device Profile (Settings → Device Profile & Verifier ID), it carries the full vendor-scoped value this identifier is derived from (the same value a pump-verification PDF carries), together with your device's name, model, and iOS version.

Retention. Activity Log entries are deleted automatically once they are older than 90 days. This is a fixed storage-hygiene limit, not a user- or admin-configurable setting. The cleanup runs when you open the App and whenever a new entry is recorded, so an entry could persist beyond 90 days only if you do not reopen the App. Independent of this automatic 90-day cleanup, you can export (CSV) or clear the entire Activity Log at any time via Settings → Activity Log.

2.3 Data That May Sync Through Your Own Apple iCloud (Optional)

If you are signed into iCloud, certain data may sync through your personal Apple iCloud account, which resides in your Apple account and which we cannot access:

• Your legacy (grandfathered/lifetime) "Pro" status, the date that access was granted, and your count of free two-person-verification initiations, via Apple's iCloud Key-Value Store, so these follow you across your devices and survive deleting and reinstalling the App (so the five free verification starts are not reset). A purchased "Pro" does not use iCloud: it is tied to your Apple ID and restored from the App Store.
• Your practice data itself (calculations, scenarios, progress) is not synced off-device; the App syncs only the small set of entitlement keys above through iCloud. Your own device backups (for example, iCloud Backup) may include App data, which we cannot access.

You can disable this in iOS Settings → [your name] → iCloud. Apple encrypts iCloud data in transit and at rest; see Apple's Privacy Policy.

2.4 Purchase Data Processed by Apple

When you buy "Pro" (a one-time purchase), Apple processes the transaction through the App Store and StoreKit. The App checks your purchase status with Apple on your device; that status is not sent to us. We receive only the aggregate sales, download, and analytics reports that Apple provides to developers, which contain nothing about an individual. We do not receive your payment card number, full billing address, or Apple ID password.

2.5 Product-Interaction Data (App Functionality)

The App processes product-interaction data on your device — e.g., feature usage needed to make the App function, such as the local counters above. This data is used only for App functionality, is not linked to your identity, and is not used to track you. It stays on your device (apart from the small set of keys in your own iCloud described in §2.3, which we cannot access) and is never transmitted to us or to any third party, so it is not "collected" in the App Store's sense. Our App Store privacy label therefore reads "Data Not Collected" (see §17).

2.6 Website (druginfusion.com)

Our marketing and support website is hosted by Vercel Inc. on our behalf. Like any web host, Vercel automatically processes standard server-log data when you visit the site — for example, your IP address, browser/user-agent, the pages requested, and timestamps — for security, reliability, and basic traffic measurement. Our website also uses Vercel Web Analytics, a cookieless, aggregate measurement service provided by our host. It records the page address, the referring page, browser, operating system, device type, and approximate location (country, region, and city) derived from your IP address, and identifies a visit by a hash of the incoming request; Vercel discards visitor sessions after 24 hours. It sets no cookies and does not track you across other websites; we use it only to understand which pages are read.

Our website also uses Google Analytics, a measurement service provided by Google LLC, to understand how visitors find and use the site. It records the pages you view, links you click (such as links to the App Store), the referring site, browser, operating system, device type, and approximate location (city and country) derived from your IP address; Google Analytics does not store IP addresses. It uses first-party cookies (named _ga and _ga_ followed by an ID) that hold a random identifier, so returning visits can be told apart from new ones. We have turned off Google Signals and the advertising features of Google Analytics, so this data is not used for advertising or personalized ads. Visitors in the European Economic Area, the United Kingdom, and Switzerland are measured without analytics cookies. Google Analytics keeps event-level data for 2 months and data linked to the cookie identifier for up to 14 months; aggregate reports that do not identify you may be kept longer. You can block Google Analytics with the Google Analytics Opt-out Browser Add-on or your browser's tracking protection. Learn how Google uses information from sites that use its services.

We do not place advertising or cross-site tracking cookies. If you contact us through the site or by email, your message is delivered through Google Workspace (Google LLC) and handled as described in §2 and §4. This website processing is separate from the App and does not involve any of your on-device practice data.

3. Information We Do NOT Collect

To be explicit, the App does not collect, store on our servers, or transmit to us:

• Patient data / PHI — no patient names, MRNs, identifiers, or any Protected Health Information. The App is a simulator; never enter real patient data.
• Identity data about you — no name, email (unless you email us), password, or account.
• Location — no precise or coarse location.
• Tracking identifiers — no IDFA/advertising identifier, no cross-app/cross-site tracking, no fingerprinting. NSPrivacyTracking is false; the tracking-domains list is empty.
• Contacts, photo library, microphone, health/fitness data (the camera is used only for live, on-device QR scanning — no images are saved or transmitted).
• Remote push notifications / device tokens — the App does not register for the Apple Push Notification service (APNs) and sends no remote push notifications, so it collects no push tokens. Any reminders (e.g., infusion-completion alerts) and Live Activities run locally on your device and are not driven by a remote server.
• Third-party analytics or crash SDKs — no Firebase, Google Analytics, Crashlytics, Sentry, Bugsnag, Mixpanel, Amplitude, Segment, ad networks, or similar. The App ships with no third-party runtime SDKs of this kind. For diagnostics the App uses Apple's own first-party, on-device MetricKit framework: crash/hang/performance payloads are processed and stored locally on your device and are not transmitted by us (see §5). Separately, Apple may provide us aggregate crash/energy reports via Xcode Organizer only if you opted in under iOS Settings → Privacy & Security → Analytics & Improvements.

4. How Information Is Used (and Legal Bases)

We (and, where applicable, Apple on your behalf) use the limited data described above to:

We do not sell or "share" personal information, use it for advertising, build commercial profiles, or make legally/similarly significant decisions about you by solely automated means.

5. Apple Services and Other Providers

The App relies on Apple's native services. Apple's processing is governed by Apple's policies, not ours.

No other third parties. Other than Google Analytics and Vercel Web Analytics on our website (§2.6), we do not integrate advertising networks, social logins, other analytics vendors, data brokers, A/B-testing platforms, or third-party crash reporting.

Platform and service providers. Platform and service providers we use for the limited data we control include Apple, Vercel, Google Workspace, and Google Analytics. None of them receives your on-device practice data.

6. Two-Person (QR) Verification

The two-person verification feature lets a partner independently double-check a calculation. It is fully offline and one-way. There is no Bluetooth, NFC, Wi-Fi, local network, or internet connection involved, and no pairing.

6.1 How it works

• Show. The first device displays a QR code containing the proposed calculation parameters.
• Scan. The partner optically scans that QR code with their device's camera (processed on-device via VisionKit).
• Check. The partner independently enters a rate; the match/mismatch is computed and shown on their own (the verifier's) device.

6.2 What the QR code contains

Only calculation parameters, for example: generic drug name; concentration; weight (if the exercise is weight-based — an educational example, not a real patient); calculation mode; proposed result (e.g., flow rate); and integrity/version metadata (a tamper-/corruption-evidence code and compatibility fields).

6.3 What the QR code does NOT contain

No patient names or identifiers, no health information, no location, no persistent device identifier, no calculation history, and no information about you.

6.4 Privacy properties

• Offline & optical only — the only "transfer" is light from a screen to a camera.
• One-way — the outcome is recorded on the verifier's device; the sender's screen is not a verification record.
• Integrity, not surveillance — the integrity code lets a device reject a damaged or altered QR. It is tamper-evidence from a bundled app key, not sender authentication, and involves no tracking.
• On-device Activity Log only — the verifier's device logs the outcome locally (see §2.2); nothing is uploaded by the App, and a practice record (PDF) of the outcome leaves the device only if you choose to share it.

6.5 Permissions

The only permission this feature uses is Camera, requested when you start scanning. Bluetooth and Local Network are not used and not requested.

7. Storage, Security, and Breach Response

7.1 Architecture

7.2 Measures

• No App data-collection servers, which structurally removes server-side breach risk for your practice data.
• On-device encryption via iOS Data Protection; cryptographic receipt verification via StoreKit 2; offline two-person verification (no wireless attack surface).
• Data minimization — we store only what the App needs to function, and the Activity Log is held to a fixed 90-day maximum age.
• No security system is perfect; we cannot guarantee absolute security, but the local-first design materially limits exposure.

7.3 Breach response

Because we hold essentially no personal data on servers, the population of data we could "breach" is extremely limited. If a security incident affecting personal data we control occurs, we will investigate and notify affected users and regulators as required by applicable law and within applicable statutory timeframes (for example, GDPR's 72-hour authority-notification standard and applicable U.S. state breach-notification laws).

8. Data Retention

Deleting the App removes local data from that device. Entitlement keys in iCloud and your purchase history with Apple persist per Apple's policies until you/Apple remove them.

9. Your Choices and Controls

• Access your data anytime in-app (Infusions, Learn, Scenarios); export the Activity Log from Settings → Activity Log.
• Export the Activity Log / calculation history as CSV (Settings → Activity Log).
• Correct/Edit entries directly in the App.
• Delete individual items, clear the entire Activity Log (Settings → Activity Log), delete all completed simulated infusions with Clear All History (Settings → Infusion History), or delete the App to remove all local data.
• Permissions — manage Camera and local Notifications in iOS Settings.
• iCloud sync — disable in iOS Settings → [your name] → iCloud → Drug Infusion.
• Purchases — view/restore "Pro" in the App's Settings; manage purchases via Apple ID.
• Crash diagnostics — controlled entirely by you in iOS Settings → Privacy & Security → Analytics & Improvements.
• Website analytics — block Google Analytics on druginfusion.com with the Google Analytics Opt-out Browser Add-on or your browser's tracking protection (§2.6).

10. U.S. State Privacy Rights

This section addresses the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and the comprehensive privacy laws of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon, Montana, and other states with comparable rights. We honor the rights below for residents of states that provide them, regardless of whether we meet a given law's applicability thresholds.

10.1 Notice at Collection (CPRA)

We do not sell or share personal information, and we do not use or disclose sensitive personal information for purposes that would trigger the CPRA "right to limit." We do not use personal information for cross-context behavioral advertising.

10.2 Your rights

Subject to applicable law, you may: know/access what we process; delete it; correct it; port it (obtain a portable copy); opt out of sale/share/targeted advertising (n/a — we do none); and not be discriminated/retaliated against for exercising rights. Most data is under your direct control in-app; for the limited data we control, contact us (below).

10.3 How to exercise rights / verification / agents

Email support@ianesthesia.org with subject "Privacy Request." We will verify your request reasonably (typically by confirming control of the email/device or purchase associated with the request) and respond within statutory timeframes (generally 45 days, extendable as permitted). Authorized agents may submit requests with proof of authorization. There is no fee for the first request in a 12-month period absent abuse.

10.4 Appeals (VA/CO/CT/etc.)

If we decline a request, you may appeal by replying to our decision email. If your appeal is denied, you may contact your state Attorney General.

10.5 California "Shine the Light" & minors

We do not disclose personal information to third parties for their direct marketing (Cal. Civ. Code § 1798.83). We do not knowingly collect or sell the personal information of minors; eligible California minors may request removal of content they posted (Cal. Bus. & Prof. Code § 22581) — though the App has no public posting feature.

10.6 No financial incentives

We offer no financial incentives or price/service differences in exchange for personal information.

11. European Economic Area, United Kingdom, and Switzerland (GDPR)

If you are in the EEA, UK, or Switzerland, the EU GDPR / UK GDPR / Swiss FADP apply.

Controller. For the limited personal data we control (entitlement status; support correspondence; website server logs), the controller is iAnesthesia LLC, 100 N Howard St, Ste R, Spokane, WA 99201-0508, United States, contact support@ianesthesia.org.

Legal bases. See the table in §4.

Your rights. Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent (without affecting prior processing). Most data is exercisable directly in-app; otherwise contact us.

EU/UK Representative. We have not appointed an EU or UK representative. You may contact us at support@ianesthesia.org. We will revisit this as our processing changes.

International transfers. See §14.

Automated decision-making. None producing legal or similarly significant effects.

Complaints. You may lodge a complaint with your supervisory authority (e.g., your national DPA; the UK ICO; the Swiss FDPIC). We ask that you contact us first.

12. Children's Privacy

Drug Infusion is intended for an adult, professional/educational audience. The minimum age to use the App is the age rating the App Store shows for the App. The App is not directed to children, and the only optional feature that relies on consent (iCloud sync) is controlled through your own Apple device settings rather than offered by us to children. We do not knowingly collect personal information from children under 13 (COPPA) or process the data of "known children" under applicable state laws, and because the App is not directed to children, the GDPR Article 8 "digital consent age" rules are not engaged. If you believe a child has provided personal information, contact support@ianesthesia.org and we will delete it.

13. Health Information / HIPAA Statement

Drug Infusion is an educational simulator. It is not intended to create, receive, maintain, or transmit Protected Health Information (PHI), and you must not enter real patient data. The Developer is not a HIPAA "covered entity" or "business associate" by virtue of the App, and the App is not offered as a HIPAA-compliant service. Any free-text field (e.g., a room label) is for your own workflow organization and must not contain identifiable patient information.

14. International Data Transfers

We do not operate App data-collection servers, so we do not ourselves transfer your practice data internationally.

Where Apple processes data on your behalf (App Store purchases; iCloud), Apple may process and store it in data centers in multiple countries under Apple's own transfer mechanisms (including, where applicable, the EU Standard Contractual Clauses and the UK Addendum).

For the limited personal data we control, processing takes place in the United States. Where we process personal data outside your country, we use appropriate safeguards where required, such as standard contractual clauses, the UK International Data Transfer Addendum, adequacy decisions, or other lawful transfer mechanisms.

15. Changes to This Policy

We may update this policy. We will revise the "Last Updated" date and, for material changes, we may provide additional notice through channels reasonably available to us — such as an in-app notice when you next open or update the App, App Store release notes, or a notice on our website. Because we do not maintain user accounts or collect email addresses, we do not notify users by email. Your continued use after the effective date of an update constitutes acceptance, except where additional consent is required by law.

Version history

We update this policy from time to time. The current version number and effective date appear at the top of this policy; earlier versions are available on request at support@ianesthesia.org.

16. Contact Us

iAnesthesia LLC

Privacy inquiries & rights requests: support@ianesthesia.org (subject: "Privacy Request")

Support: https://www.druginfusion.com/support

Mailing address: 100 N Howard St, Ste R, Spokane, WA 99201-0508, United States

Target response time: within 5 business days (statutory deadlines control where applicable).

17. Apple App Store Privacy Label (Nutrition Label) Mapping

Our App Store privacy label reads "Data Not Collected" (NSPrivacyTracking = false — we do not track you). The App has no user accounts, runs no servers that receive your data, and contains no third-party analytics, advertising, or crash-reporting SDKs; your practice data stays on your device. The privacy manifests for the App and its widget declare no collected data types. In the label's terms:

• Data used to track you: None.
• Data linked to you: None.
• Data not linked to you: None. Product-interaction data (§2.5) is kept on your device (and in the §2.3 keys in your own iCloud) and is never sent to us, so it is not "collected" in the App Store's sense.
• Purchases: handled by Apple; Apple's own disclosures cover payment data.

This label describes the App. Standard server logs and the website analytics described in §2.6 are a website matter, separate from the App's App Store privacy label.

Drug Infusion is an educational simulator. It is NOT a medical device and NOT intended for clinical decision support, diagnosis, treatment, or patient care. All drug information and calculations are for educational practice only.