Privacy Policy

Date of Publication: August 5, 2026 | Last Updated: October 8, 2026

Introduction

This Privacy Policy (this “Policy”) describes how FlightPath Innovations LLC, a Utah limited liability company doing business as FPI Medical (“FPI,” “Company,” “we,” “us,” or “our”) collects, processes, retains, and discloses information when providing services through the publicly accessible, unauthenticated area of our website at fpimedical.com (the “Website”), the authenticated, role-restricted area of fpimedical.com (the “Application”), and related services that link this policy (the “Services”).

This Policy applies only to information we collect:

  • Through the Website, the Application, or the Services.
  • In communications, including email, text, chat, and other electronic messages, between you and FPI.

It does not apply to information collected:

  • By us through any other means, including on any other website operated by FPI or any third party that does not link to this policy; or
  • By any third party, including through any application or content that may link to or be accessible from or through the Website, the Application, or the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this Policy carefully to understand our policies and practices regarding information we collect and how we treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using the Website, the Application, or the Services, you agree to this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website, the Application, or the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Section 1: Information We Collect

1.1. Personal Information

“Personal Information” is information that identifies, relates to, or describes, directly or indirectly, you, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, credit card number, social security number, or any other identifier we may use to contact you online or offline). Personal Information includes, without limitation, the categories of information described in Sections 1.2 (Website Visitors) and 1.3 (Clinics and Authorized Users) below.

1.2. Website Visitors

When you visit the Website or interact with our marketing materials, we may collect:

(a) Information You Provide Directly:

  • Name, email address, phone number, and clinic name (via contact/demo request forms)
  • Any other information you voluntarily submit

(b) Information Collected Automatically:

  • IP address and device information
  • Browser type and version, operating system
  • Pages visited, time spent on pages, referring URL
  • Cookies and similar tracking technologies
  • Google Analytics data

1.3. Clinics and Authorized Users

When Clinics (as defined in the Subscription Agreement) and Authorized Users (as defined in the Subscription Agreement) register for and use the Application, we collect:

(a) Information You Provide Directly:

  • Name, email address, role, clinic assignment, credentials
  • Billing name and address (via subscription registration)

(b) Information Collected Automatically:

  • IP address and device information
  • Browser type and version, operating system
  • Pages visited, time spent on pages, referring URL
  • Audit log data (actions taken within the Application)
  • Payment and billing information

1.4. How We Collect Information

We collect information directly from you when you provide it to us; automatically as you navigate through the Website or Application (including usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and from third parties, for example, our business partners including Google Analytics. The information we collect automatically is statistical data and does not identify any individual. It helps us improve the Website and Services and deliver a better and more personalized service by enabling us to estimate our audience size and usage patterns, store information about your preferences, speed up your searches, and recognize you when you return.

Section 2: How We Use Information

2.1. Website Visitor Information

We use Website Visitor Personal Information to:

  • Respond to inquiries and demo requests
  • Communicate with you about our Website or Services
  • Analyze website traffic and provide, maintain, and improve the Website and Services
  • Prevent fraud and ensure security
  • Comply with legal and regulatory obligations
  • Fulfill any other purpose for which you provide it, or for any other purpose with your consent

2.2. Clinic and Authorized User Information

We use Clinic and Authorized User Personal Information to:

  • Authenticate users and manage access
  • Communicate about the Application or Services, including transactional notifications and changes to the Application or Services
  • Process payments and manage subscriptions
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection
  • Provide, maintain, and improve the Application and Services
  • Generate audit logs for compliance and security
  • Investigate and respond to Security Incidents (as defined in the Subscription Agreement)
  • Comply with legal and regulatory obligations

2.3. Aggregated and De-Identified Data

FPI may create aggregated, de-identified, or anonymized data from Website or Application usage that cannot identify any individual. FPI may use such data for product improvement, benchmarking, and analytics purposes without restriction. De-identification is performed in accordance with 45 C.F.R. § 164.514.

Section 3: Cookies and Tracking Technology

3.1. Website Cookies

The Website uses cookies and similar technologies for the following purposes. Non-essential cookies are blocked until you consent through the cookie banner, and you may change your choices at any time through the cookie preference center.

  • Strictly Necessary: Session management, authentication state, security, and storing your cookie consent preferences
  • Analytics: Google Analytics 4 cookies for website performance and usage analysis
  • Functional: Membership and session features provided through our membership platform

A cookie is a small file placed on the hard drive of your computer. We use Google Analytics to analyze user activity in order to improve the Website. For example, using Google Analytics we can look at aggregate patterns like which pages are visited most, and use that analysis to gain insights about how to improve the functionality and experience of the Website. For further details, please see Google’s privacy compliance page: https://privacy.google.com/businesses/compliance/

Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

3.2. Application Cookies

Cookies used in the Application area are limited to strictly necessary and functional cookies used for authentication, security, and membership features. The Application does not use analytics, advertising, or tracking cookies.

3.3. Do Not Track / Global Privacy Control

You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting or a Global Privacy Control (GPC) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. FPI does not currently respond to DNT or GPC signals except to the extent required by applicable state law. You may decline analytics cookies at any time through the cookie preference center on the Website.

Section 4: How We Share Information

4.1. Aggregated and De-Identified Data

We may disclose aggregated, de-identified, or anonymized data, and other information that does not identify any individual, as described in Section 2.3 (Aggregated and De-Identified Data) for purposes such as product improvement, benchmarking, and analytics.

4.2. Personal Information

We may disclose Personal Information that we collect or that you provide as described in this Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. Any service provider that may access Protected Health Information, including website development and hosting providers, does so only under a Subcontractor BAA (as defined in the Subscription Agreement) and only to the extent necessary to support the Website, the Application, or the Services.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FPI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by FPI is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to these disclosures.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information, provided such purpose is consistent with the context in which the information was collected.
  • With your consent.

4.3. Legal Obligations

We may also disclose Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Service or Subscription Agreement and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others.

4.4. No Sale of Personal Information

FPI does not sell Personal Information or share Personal Information for cross-context behavioral advertising. We do not share your information for third-party advertising.

Section 5: How We Protect Your Information

5.1. Security Measures

We use commercially reasonable administrative, technical, and physical safeguards designed to protect information processed by FPI through the Website or Application from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Information you provide to us is stored on our secure servers behind firewalls, and any payment transactions will be encrypted using SSL technology. Our security program is subject to periodic third-party audits, including SOC 2 Type II assessments.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

5.2. No Guarantee of Absolute Safety

While we strive to protect Personal Information and Protected Health Information (as defined in the Subscription Agreement), no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security or that data will never be compromised. Any transmission of personal information is at your own risk. Pilots or other Individuals (each as defined in the Subscription Agreement) should notify their Clinics immediately of any suspected unauthorized access to sensitive data.

5.3. Data Retention

We keep the categories of Personal Information described in this Policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Website or Application, providing the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain data. Information submitted through Website contact and demo request forms is retained for twelve (12) months. Customer Data (as defined in the Subscription Agreement) is retained and deleted in accordance with the Subscription Agreement, the Clinic BAA, and applicable law.

Section 6: Your Rights and Choices

6.1. Your Rights

Depending on your jurisdiction, you may have certain rights with respect to your Personal Information, including:

  • Access and Data Portability. You may confirm whether we process your Personal Information and access a copy of the Personal Information we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
  • Correction. You may request that we correct inaccuracies in your Personal Information that we maintain, taking into account the information’s nature and processing purpose.
  • Deletion. You may request that we delete Personal Information about you that we maintain, subject to certain exceptions under applicable law.
  • Opt-Out Rights. You may request that we do not use your Personal Information for sales, targeted advertising, or profiling for certain legal or similarly significant decisions.

To exercise any of these rights, please contact us at support@fpimedical.com. We will respond to verifiable requests within forty-five (45) days of receipt, or such other timeframe as required by applicable law. We may request additional information to verify your identity before processing your request. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you have an account, you may also be able to review and change your personal information by logging in and visiting your account profile page.

6.2. State Privacy Rights

You may have additional privacy rights under state law, depending on where you live. Because state privacy legislation continues to evolve, additional privacy rights may become applicable to you depending on your state of residence. FPI is committed to complying with applicable state privacy laws and will update this Policy as necessary to reflect new legal requirements. If you believe you have privacy rights under the laws of your state that are not addressed in this Policy, please contact us at support@fpimedical.com and we will work with you to address your request in accordance with applicable law.

6.3. HIPAA Preemption

To the extent Personal Information is subject to HIPAA, such information is governed by HIPAA and the Clinic BAA (as defined in the Subscription Agreement). Where HIPAA applies, it may preempt state privacy laws that are contrary to HIPAA and less protective of individual privacy; however, state laws that provide greater privacy protections than HIPAA remain in effect.

6.4. Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@fpimedical.com.

Section 7: Children’s Privacy

The Website, the Application, and the Services are not directed at children under the age of 13, and FPI does not knowingly collect personal information from children under 13. No one under age 13 may provide any personal information to or through the Website, the Application, or the Services. The Application and related Services are designed for use by licensed U.S. medical clinics and their authorized personnel in connection with FAA-regulated pilot medical examinations.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information at the bottom of this page.

Section 8: International Users

The Website, Application, and related Services are currently offered for use within the United States only and are hosted on U.S.-based infrastructure. FPI does not currently offer the Application or related Services to clinics located outside the United States.

If you access the Website or the Application from outside the United States, you do so at your own risk. By accessing or using the Website or Application from a location outside the United States, you acknowledge and agree that:

  • Your information will be transferred to, stored, and processed in the United States, which may not offer the same level of data protection as your home country;
  • You acknowledge that your information will be processed in the United States, which may not offer the same level of data protection as your home country, and that FPI’s obligations under this Policy are governed by U.S. law;
  • You will not assert any claim against FPI based on the data protection or privacy laws of any jurisdiction other than the United States; and
  • This Policy, including the rights and obligations described herein, is governed exclusively by the laws of the State of Utah and applicable U.S. federal law, without regard to conflict of law principles.
  • FPI makes no representation that the Website, Application, or related Services are appropriate or available for use in locations outside the United States. Access from jurisdictions where the content or use of the Website, Application, or related Services is illegal or restricted is prohibited.

Section 9: Miscellaneous

9.1. Changes to Our Privacy Policy

FPI may update this Policy from time to time. Material changes will be communicated at least thirty (30) days prior to taking effect via the contact information associated with your account (for Clinics and Authorized Users) or by posting the updated Policy on the Website. The “Last Updated” date at the top of this Policy will be revised to reflect the date of the most recent update. Continued use of the Website, the Application or Services after the effective date of any material change constitutes acceptance of the updated Policy. If you do not agree to any material change, you may terminate your use of the Website, Application, and/or Services before the change takes effect. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting the Website and this Policy to check for any changes.

9.2. Contact Information

For questions, concerns, or requests regarding this Policy or FPI’s privacy practices, please contact us:

FlightPath Innovations LLC (dba FPI MEDICAL)

3081 E 3300 S Ste 5 #123
Millcreek, UT 84109

810-280-2508

support@fpimedical.com

9.3. Relationship to Other Agreements

This Policy is incorporated into the Terms of Service and Subscription Agreement. This Policy is intended to provide transparency regarding FPI’s data practices and does not create independent rights for third parties beyond those required by applicable law. In the event of any conflict between this Policy and the Clinic BAA with respect to Protected Health Information, the Clinic BAA shall control.

9.4. Governing Law

This Policy is governed by the laws of the State of Utah, consistent with the Website Terms of Service and Subscription Agreement.

9.5. Severability

If any provision of this Policy is held invalid or unenforceable, the remaining provisions shall continue in full force and effect.