Terms of Service

If this is an emergency, stop reading

If you think you may be having a medical emergency, call 911 or go to the nearest emergency department. For a suicidal or mental-health crisis, call or text 988.

Gale is not monitored in real time and cannot connect you to emergency services. Do not use Gale's chat, messages, symptom search, screening tools, or scheduling to report an emergency. We may not see it in time. Section 2 has the full list of crisis resources.

Status of this document — read this second

One commitment you can rely on from the first sentence: Gale will never use your personal or health information for advertising or marketing, and will never sell it. Not the fact that you looked for care, not what you searched, not what you read, not your email address. Section 11.3 says exactly what that means and exactly how far it goes.

These Terms describe the relationship that will govern when Gale serves real patients, and they govern your use of Gale today. Where a commitment below is architectural — built into the software and provable — we say so. Where it is a promise about the future, we say that instead. Where Gale's software does not yet do something this document describes, we say that, in the body, in plain words. We have tried not to leave a single unflattering fact in a footnote.

What is in this document

0. Accepting these Terms

You accept these Terms by checking the box marked "I agree to Gale's Terms of Service and Privacy Policy" and clicking "Create account." If you do not accept them, do not create an account.

We keep a record of your acceptance: your account id, the date and time, and the exact version of these Terms you were shown. The version you are reading is 1.0, effective July 14, 2026.

"You" means the person using Gale — a patient, a person acting for a patient they have authority for, a clinician, a practice's staff member, or anyone else who creates a Gale account or uses Gale's public surfaces. Where a section applies to only one of those, it says so.

1. What these Terms cover — and what they do not

These Terms are a contract between you and Gale Care Inc. ("Gale," "we," "us") about your use of the Gale software, which is defined in Appendix A: the website at gale.care, the Gale apps, the patient portal, the health library, symptom search, the screening tools, the chat, the care-finding tools, and the software a clinician's practice uses to run its practice. It does not include medical care, which is provided by a clinician and their practice, not by Gale.

These Terms are not, and are not intended to be, any of the following. This matters, so we will say it plainly rather than bury it:

• They are not your consent to medical treatment. Consent to treatment is your clinician's act, done on your clinician's own form, under your state's law. Gale cannot consent you to care it does not provide.
• They are not a Notice of Privacy Practices. Under HIPAA that notice belongs to your clinician's practice, which is the Covered Entity (45 C.F.R. § 164.520). Gale is the practice's Business Associate. Gale cannot issue a privacy notice for care it does not give.
• They are not your consent under any consumer-health-data law. Washington's My Health My Data Act (RCW 19.373) provides that consent to collect consumer health data may not be obtained as part of a terms of use. We do not try to get it here. Any such consent is asked for separately, in its own place, as its own act.
• They are not your consent to be called or texted. We ask for that separately, where you give us your number, and you can decline. See Section 8.
• They are not an agreement to arbitrate a claim against your clinician. Nothing in Section 19 covers, or is intended to cover, a claim of professional negligence against a clinician or a practice. Whether you have any arbitration agreement with your clinician is between you and them, on their form, under the formalities their state requires (in California, for example, Cal. Code Civ. Proc. § 1295).

2. Emergencies — Gale is not for them

If you think you may be having a medical emergency, call 911 or go to the nearest emergency department.

• 988 — Suicide & Crisis Lifeline. Call or text 988. Free and confidential, 24/7, for suicidal thoughts, a mental-health crisis, or emotional distress — for you or someone you care about. (988 is the federally designated lifeline under the National Suicide Hotline Designation Act of 2020, Pub. L. 116-172.)
• Crisis Text Line. Text HOME to 741741 to reach a trained crisis counselor by text, 24/7.
• Poison Control. Call 1-800-222-1222 for a suspected poisoning, overdose, or harmful exposure, 24/7.

Gale is not monitored in real time and cannot connect you to emergency services. Do not use Gale's messages, chat, symptom search, screening tools, or scheduling to report an emergency. We may not see your message in time.

If Gale's software detects language suggesting an emergency or self-harm, it routes you to these resources. It will not offer you a booking link and it will not place a phone call for you on that path. This one is architectural. Gale's outbound-call code refuses an emergency before it touches any telephone vendor at all — the refusal is the first check in the function, and there is no way around it. An emergency never dials.

3. Gale is software. Gale does not practice medicine.

3.1 Your clinician and their practice

Gale Care Inc. builds and operates the technology a clinician's practice uses — scheduling, records, visits, notes, billing. Gale does not diagnose, does not prescribe, does not choose your treatment, and does not supervise or direct the clinical judgment of any clinician.

Your clinician practices through their own licensed professional practice, which they own. That practice — not Gale — holds your medical record, sets its own clinical policies, sets its own fees, decides whether to accept you as a patient, and is responsible for your care. Clinicians who use Gale are independent; they are not Gale's employees and Gale does not direct their medical judgment.

If you have a question about your care, ask your clinician. If you have a question about the software, ask us.

3.2 What Gale does

Gale provides administrative and technical services: search and scheduling; a patient portal; secure messaging; the video and audio connection for a visit; an ambient scribe that drafts a note for the clinician to review and edit; billing and revenue-cycle workflow; payment processing through Stripe; and a public health library. Gale's practice-management automation is administrative only. Where Gale surfaces anything that looks like a clinical recommendation, a named licensed clinician owns that decision and can see the basis for it.

3.3 HIPAA — the practice is the Covered Entity; Gale is its Business Associate

Under HIPAA, your clinician's practice is the Covered Entity and Gale is its Business Associate. That means Gale handles your health information on the practice's behalf and under the practice's instructions, subject to a written Business Associate Agreement required by 45 C.F.R. §§ 164.502(e) and 164.504(e).

This is the opposite of a platform that owns a medical group and treats you itself. Gale does not own a medical group. Gale is a vendor to your clinician's practice.

Not everything on Gale is HIPAA data — and the line is about where your information goes, not which page you were on.

• If information about you is held by Gale on your clinician's practice's behalf — your chart, your note, your claim, anything Gale puts into or takes out of your record — it is protected health information, and HIPAA governs it.
• If information about you is collected by Gale on its own account, outside any practice's record — what you read in the health library, what you type into symptom search, a screener you take and never share with a clinician, a chat you have before you are anyone's patient — there is no Covered Entity behind it and HIPAA does not reach it. That information is governed by state consumer-health-data law and by our Privacy Policy.

The same act can cross the line. A screener result you choose to send to your clinician starts as consumer health data and becomes part of your medical record. We tell you at the moment you cross it.

This split is the most important structural fact about how your information is handled. The Privacy Policy describes it in full. Read it.

3.4 Gale will never use your information for advertising or marketing

Gale does not offer a marketing authorization, because Gale will never use your personal or health information for marketing or advertising. There is no form you could sign that would let us. See Section 11.3, which states the promise in full and does not narrow it anywhere.

4. Information on Gale is not medical advice

4.1 The health library, symptom search, and the screening tools

Gale's health library, symptom search, and screening tools (for example PHQ-9, GAD-7, AUDIT-C) give you general health information to help you understand your options and prepare for a conversation with a clinician.

• They do not diagnose you.
• They do not tell you what treatment you need.
• They are not a substitute for care from a licensed clinician who knows you.
• A screening tool result is not a diagnosis. It is a self-administered questionnaire you scored yourself.

A visit is different. When you see a clinician through Gale, that is real medical care — provided by that clinician and their practice, not by Gale.

4.2 Gale's chat

Gale's chat is an AI assistant. It is there to help you understand health information, find your way around the product, prepare questions for a clinician, and get to a human. It is not therapy, not counseling, not psychotherapy, and not a substitute for a clinician. It will not diagnose you, will not give you a drug and a dose, and will not give you a treatment recommendation to act on without a clinician.

Here is what happens to what you type, and we are not going to soften it.

• Your identifiers come out before the message leaves your browser. The health content does not. Your name, phone number, email address, street address, dates, and record numbers are replaced with placeholders on your own device; Google and Gale's own database see only the placeholdered text, and the key that restores your real words never leaves your device. But the health content of your question still goes to Google — it has to, or there is nothing to answer. Do not treat the chat as anonymous.
• The health content of what you type is sent to Google, which runs the AI model. Gale stores the placeholdered conversation.
• When the chat looks something up to answer you, your question is sent to Google Search. You can see when it did that — the chat cites what it found.
• Gale sends this text to Google's Gemini model on Vertex AI, which is covered by the Google Cloud HIPAA Business Associate Addendum Gale signed on 13 July 2026. Until that day the text went to Google's consumer AI endpoint, which that agreement does not cover; we moved it to Vertex AI — the HIPAA-eligible version of the same model — the same day. The agreement governs what Google may do with the text; it does not stop the text being sent, and the health content of your question still goes to Google, because there is nothing to answer otherwise.

4.3 Plans you build from research papers

In the Gale app you can state a goal in your own words, choose research papers about it, and ask Gale to draft a plan from the papers you chose. Section 6.5 describes how it works and where the words go.

It is general health information, not personalized medical advice. That is the sentence the app itself puts on the draft and on the plan, and we are not going to write a softer one here.

• It is not a diagnosis and not a prescription. It carries no drug and no dose.
• No clinician has reviewed it. It was assembled from sources you selected — not by, or checked by, a licensed professional who knows you.
• Research describes populations; it does not know you. Where a paper says who it studied, the draft says so; where the paper does not say, the draft says that instead of guessing. A study of adults is flagged as a study of adults.
• It is a proposal until you accept it. Nothing exists as a plan until you press Create, and every line is yours to change or delete before and after.
• Take it to your clinician before you act on it, especially alongside a medicine, a condition, or a pregnancy. Nothing in the draft is a reason to start, stop, or change a treatment on your own.

5. Your account

5.1 Eligibility and age

You must be 18 or older to create your own Gale account.

5.2 Accounts for other people — and the minor-confidentiality gap we have not closed

An adult may hold an account on behalf of a minor child or another person for whom they have legal authority. If you do, you represent that you have that authority.

Gale's software does not yet enforce a minor-confidentiality firewall. You need to know that before you use a family account.

Your state's law may give a minor the right to consent alone to some kinds of care — in many states that includes mental health, reproductive care, substance use, and care for sexually transmitted infections — and to keep that care private from a parent or guardian. Gale has not yet built the software that enforces those rules. An adult holding an account for a minor may today be able to see information that the minor's state would keep private. We would rather tell you that than let a sixteen-year-old assume a wall exists that does not.

When we build it, here is the rule it will follow, because it is the right rule and it is the one our own Constitution requires:

• For a category of care a minor may consent to alone under their state's law, a guardian's proxy access is restricted.
• The minor keeps full access to their own record.
• The guardian keeps access to everything that is not one of those protected categories.
• What is protected is set by state law, by service, and by age — not by a fixed list we invent.

5.3 Accurate information — including your physical location

You agree to give accurate information and keep it current. This is load-bearing for one field in particular: where you physically are.

Telehealth is lawful only where the clinician is licensed and where you are physically located. So at the start of every visit — not once at sign-up — Gale asks you to confirm the state you are physically in, and checks that state against your clinician's active licenses before the visit room opens. If your clinician is not licensed where you are, the room does not open. It does not silently proceed.

Gale relies on your word. Gale does not independently verify your location. We do not use your IP address, your device's GPS, or any other signal to check where you are; the check is against the state you select, and nothing else. That is why the next sentence matters so much.

Misstating your location is a material breach of these Terms and can make an otherwise lawful visit unlawful. Do not do it.

We use the state you give us only to check that your visit is lawful. We do not use it for advertising, we do not build a location history from it, and we do not sell it.

5.4 Security

Keep your credentials secret. You are responsible for activity under your account. Tell us immediately at legal@gale.care if you believe your account has been compromised.

6. Artificial intelligence in Gale — disclosure

Gale uses AI in four places you can see. We are telling you where, what it does, and what it does not do.

6.1 The ambient scribe

If your clinician uses Gale's ambient scribe, it listens during your visit and drafts a note. The clinician reads, edits, and signs that note. The clinician's edit is the record. An AI-drafted note is never sent to you, and never becomes part of your chart, without a licensed clinician reviewing it first. That human review is structural and Gale will not remove it.

How the scribe handles audio — the honest, two-path version:

• On iPhone: the audio is transcribed on the device. The audio does not leave the phone.
• On the web: the audio is sent to Gale and on to Google's Speech-to-Text service to be turned into text. The audio at that point still contains the names that were spoken. Then the resulting text is de-identified on your clinician's device — names, dates, and other identifiers are replaced with placeholders — before the note-drafting model sees it. The key that maps a placeholder back to a real name stays on the clinician's device and is never transmitted.

We are describing this precisely because the shorter version — "identifiers are removed before anything reaches the cloud" — is true on iPhone and not true on the web.

Gale does not store visit audio. There is no code in Gale that uploads visit audio to Gale's storage; the web path streams it through Gale's server to Google's Speech-to-Text service and keeps nothing. That service is covered by the Google Cloud HIPAA BAA we signed on 13 July 2026, and Gale is not enrolled in Google's Speech-to-Text data-logging program, so the audio is not retained to improve Google's products.

6.2 The chat and the care-finding assistant

Both are AI. Both are disclosed as AI. Neither will ever claim to be a person, and both will answer truthfully if you ask. Neither uses a clinical title, a clinical credential, or any design element implying it holds a health-care license — that is prohibited by California AB 489 (2025).

Gale's care routing — the part that decides which kind of care your search suggests — does not use an AI model at all. It is a fixed, deterministic rule table.

6.3 Calls Gale places for you — a feature that does not work yet

Gale does not place calls today. No call has ever been placed. The feature you may see described in the product — where you ask Gale to call a provider's office on your behalf — is built up to the point of dialing and then stops. Gale's code writes a record of the request and honestly refuses to dial, because the calling transport is not connected. Saying otherwise would be a lie about the most sensitive thing in the product, so we are not going to say otherwise.

Two things about it are true and structural today:

• An emergency never dials. Gale's call function refuses an emergency before it touches any vendor.
• The feature is gated three ways at the server. Even when the transport is connected, Gale's software will place a call only from an allowlisted caller, only to an allowlisted destination, and only for an identity explicitly flagged as a synthetic demonstration identity. An unflagged identity is treated as a real person and the call is refused. It cannot call an arbitrary office. The gate lifts only when the Business Associate Agreements in Section 14 are signed.

When it ships, here is what it will do, and we are writing it down now so that you can hold us to it:

• Before anything else is said on the call, a fixed announcement will play. It will name Gale Care Inc., give a callback telephone number for Gale (+1 (617) 271-2159), state that the caller is an automated AI assistant, state whether the call may be recorded, state that you may be listening and may join, and offer the office the chance to decline the call. The first two of those are required of every artificial-voice call by 47 C.F.R. § 64.1200(b)(1)–(2); the rest are ours. The announcement will be a structural precondition of the dial — not a prompt the model can skip.
• The assistant will never claim to be you, never claim to be a person, never claim to be practice staff or a licensed professional, and will answer truthfully if asked whether it is an AI.
• It will tell the office only what you have agreed it may say — at most your name, date of birth, a callback number, your insurance, and the general type of care you are looking for.
• It will never promote Gale on the call.
• It will never be used in an emergency or a crisis.
• Where an automated call uses an artificial voice, California AB 2905 (2024) requires the announcement to disclose that the message was generated using AI. Gale's will.

Who else would hear that call. The call would be carried by a telephony vendor (Twilio) and the AI voice produced by a third-party model vendor (OpenAI). The live audio of the call — your voice, and the office's — would be processed by both. Neither has signed a Business Associate Agreement with Gale. That is one of the reasons this feature is gated.

And one thing you should know about your own phone. If you ask Gale to call an office for you, the design is that Gale calls you too, so that you can listen and join. That means a Gale-initiated call — with an AI voice on the line — would ring your phone. That will only ever happen because you asked for it, on a call you requested, and never for marketing. Section 8 covers every other message Gale might send you.

6.4 What Gale's AI never does

Across every surface: Gale's AI navigates, educates, schedules, and hands you to a human. It never outputs a diagnosis, never gives a drug and a dose, and never gives a treatment recommendation for you to act on without a clinician. It never independently predicts a time-critical clinical event and never analyzes an image or a physiologic signal to tell you what is wrong with you.

That sentence governs what Gale offers you unprompted. It does not govern what you ask Gale to build for you. If you direct Gale to assemble something from sources you picked, the result is your material — Gale's role is assembly at your direction, and the thing that comes out is yours to edit, keep or throw away. Gale's Constitution records this as ruling PC-2: a plan you create in the app is user-generated content, not Gale's clinical output.

One surface needs a more precise sentence than the general one, and we would rather write it than let the general sentence quietly stop being true. If you ask Gale to draft a plan from research papers you chose (Section 6.5), the draft proposes steps and a schedule. That is more than "education", and we are not going to describe it as less. What stays true of it: it is built only from sources you selected; every line cites one of them; it carries no drug and no dose; for a child, a medication, supplement or dose step is not composed at all; it is not a diagnosis and not a prescription; no clinician has reviewed it; it is disclosed on the screen as drafted by Gale from the papers you chose; and it is not a plan until you press Create. Section 4.3 is the not-medical-advice statement that goes with it.

6.5 Composing a plan from papers you chose

This runs only when you start it. Gale never composes on its own and never writes your goal for you. A button you tap — "start a plan from this" — is an offer; the goal is still yours to type. And Gale never pre-selects a paper: a paper handed in from somewhere else in the app arrives highlighted but unchecked, every row in the picker opens unchecked, and your tick is what selects it.

How it works, in order:

1. A safety check runs first. Before any search and before any model is called, what you typed is checked for a crisis. If it looks like one, you get the crisis card — no search, no draft, nothing filed.
2. Your identifiers come off on your device. Your goal and your later messages are scrubbed on your own device before anything is sent, and our server independently refuses the request if an identifier shape survives — it refuses; it does not silently repair.
3. The papers come from Gale's own index. The shelf runs on Gale's own servers, and no search company receives your query — there is no search company. See Section 14, and Section 13.5 for where the papers themselves come from.
4. The draft is composed by Google's Gemini model on Vertex AI, under the healthcare agreement of 13 July 2026 — from your scrubbed goal and the abstracts of the papers you ticked, and from nothing else.
5. The draft is checked before you see it. If it breaks Gale's own language rules — a dose, a promise about what will happen, a command aimed at you — the draft is withheld and the conversation continues. You are not shown unchecked model text.
6. Preprints are labelled, and cannot carry a line alone. A paper that is not yet peer-reviewed is marked as such wherever it appears, and a step, outcome or risk supported only by preprints is left out of the draft.
7. Nothing exists until you press Create. The draft lives on your device. No plan, no step, no reminder and no notification is created on our servers before you accept it — and you can throw the draft away in one tap.
8. If you create it, we record where it came from: which papers, when, and which model. That record is written by our server, not claimed by the app.

If your AI-data switch is off, this feature is unavailable — Gale tells you so and offers to build the plan by hand. It never runs the feature anyway.

7. Recording

Your visit. Your clinician may use Gale's ambient scribe. Your clinician is required — by their own professional obligations and by their agreement with Gale — to ask your permission before using it, and you can say no. Declining does not affect your care.

We are going to be honest about the limit of that promise: Gale's software does not currently enforce that step. There is no gate in the code today that stops a scribe from starting until a patient consent is recorded. We are building that check. If a scribe was used in your visit without anyone asking you, tell us at legal@gale.care.

Gale does not store visit audio. On iPhone the audio never leaves the device. On the web, the audio is sent to Google's Speech-to-Text service to be turned into text — which is covered by the Google Cloud HIPAA BAA we signed on 13 July 2026, and Gale is not enrolled in its data-logging program, so the audio is not kept to improve Google's products. We would rather say that than let the bold sentence do more work than it can carry. See Section 6.1.

Calls Gale places for you. Gale does not record these calls. Gale does not place these calls at all yet (Section 6.3). Recording is off, it is off by construction — the value is a fixed false in the code — and no per-state recording-consent policy has been built. If Gale ever enables recording on these calls, it will do so only under a per-state consent rule, and it will tell you before it does.

Recording law is a state-law question and the strictest party's law governs. California Penal Code § 632, for example, makes it a crime to record a confidential communication without the consent of all parties, and California Penal Code § 637.2 supplies a civil remedy.

8. Calls, texts, and email

Care messages come from your clinician's practice. When you become a patient of a practice that uses Gale, giving that practice your phone number is your consent for the practice — and for Gale sending on the practice's behalf under a Business Associate Agreement — to call or text you about your care: appointment reminders, instructions, results. That is how the FCC treats a phone number given to a health-care provider. Your consent to that is given to the practice, on the practice's form, not here. These Terms do not take it for them.

Messages from Gale itself: email about the things you asked us for. If you created an account, Gale may email you about your own activity here — the answer to something you searched, an appointment opening in your state, the fact that a record you own can travel with you. Gale does not text you and does not call you. Push notifications, if you turn them on, are a separate permission your phone asks for directly, and turning them off in your phone is enough to stop them.

What Gale will not send you, ever: marketing. Not because you have not opted in — because we do not do it, and Section 3.4 says there is no form you could sign that would change that. In practice that means some things we could build, we do not send. If a message would use what you ate, or searched, or read in order to sell you on a feature, it does not go out, even to someone who would probably like it.

Gale is not yet a business associate of any practice and does not yet send care messages on any practice's behalf. Care messages — appointment reminders, instructions, results — come from your clinician's practice, on the practice's consent, as described above.

Billing messages are different from care messages, and consent for them is asked separately.

How to stop — and what is actually built today. You have the right to withdraw consent at any time and by any reasonable means, and you now have three that work:

• One click in any email. Every message carries an unsubscribe link that works without signing in. It stops everything, on every channel, immediately.
• Your settings. Choose what you hear about and how often, or turn it all off, at gale.care/preferences or in your account settings.
• Email us. Write to legal@gale.care and we will turn the messages off.

Automatic handling of a texted STOP is still not built — which is why Gale does not send text messages at all. We will honor any opt-out as soon as we can and never later than 10 business days, and unless you tell us otherwise it applies to all of our automated messages. Withdrawing consent does not affect your care.

Marketing. Gale does not use your personal information or your health information to market to you. Not the fact that you looked for care. Not what you searched. Not what you read. Not your email address. Not your account. This is not a right we are reserving and plan to exercise later — it is a hard commitment, stated at full width in Section 11.3, and it is not narrowed anywhere in this document.

9. Telehealth

9.1 It has to be lawful in two places

A telehealth visit must be lawful both where you are physically located and where your clinician is licensed. Gale checks this before the visit connects. Gale surfaces the interstate licensure compacts honestly: they exist for some professions and not others, and where none exists, cross-state practice means an individual state license. Gale will not tell you a shortcut exists when it does not.

9.2 Your location, every time

See Section 5.3. Location is captured at every visit, not once at sign-up — and it is captured as your attestation, which Gale does not independently verify.

9.3 Controlled substances

Whether a clinician may prescribe a controlled substance without an in-person examination is governed by federal law, by the DEA, and by your state. The in-person examination baseline set by the Ryan Haight Act is the durable rule. The DEA's telemedicine flexibility is a temporary, repeatedly-extended status — currently extended through December 31, 2026 — and Gale treats it as current and subject to change, not as settled law. Your clinician decides what to prescribe. Gale does not.

9.4 When telehealth is not right

Your clinician may end a telehealth visit and ask you to be seen in person. That is a clinical judgment and it is theirs to make. In-person care is not a telehealth clone — different licensing, facility, and consent rules apply, and Gale applies the right check for the visit type.

10. Money — what you pay, and to whom

You pay the practice, not Gale. Your clinician's practice sets its own fees. Gale processes the payment on the practice's behalf.

• Estimates. If you are uninsured or paying out of pocket, the No Surprises Act entitles you to a Good Faith Estimate of expected charges. That estimate is your clinician's practice's to give you — it is their charge and their obligation, not Gale's. Gale builds the software the practice uses to produce it and to get it to you. The Good Faith Estimate requirement is codified at 45 C.F.R. § 149.610; if the practice's billed charges come in $400 or more above the estimate, you may invoke the patient-provider dispute resolution process under 45 C.F.R. § 149.620.
• Payment processing — and how the money actually moves. Payments are processed by Stripe, subject to Stripe's terms. The charge is created on Gale's own Stripe platform account, and the amount owed to your clinician's practice is then transferred to the practice's own Stripe Connect account, net of Gale's platform fee. We are correcting an earlier, friendlier description of this: the money does pass through Gale's Stripe platform account. What is true is that Gale does not keep your professional fee or your payment — Gale deducts only its stated platform fee (Appendix B, § B.5) and the rest goes to the practice.
• What Stripe sees. The payment payload Gale sends to Stripe carries an amount, a currency, and opaque identifiers. Clinical detail — your diagnosis, your procedure codes, the link to your visit — structurally cannot enter it. That is enforced by a single chokepoint in Gale's code that rejects any payload containing it, in both test and live mode. It is not a policy we remember to follow.
• Card on file. If you allow the practice to keep a card on file, you sign a separate consent for that, and that consent is checked again at the moment of any charge. A charge above your Good Faith Estimate is held for review rather than run.
• Refunds and disputes. These are between you and the practice. Gale will help the practice process them.

What Gale charges the practice is set out in Appendix B, § B.5, which is part of our agreement with the practice, not with you. It is never charged to you.

11. Your health information, your record, and research

The complete account is in the Privacy Policy, which is incorporated into these Terms. This section is the short version of the four things people most want to know.

11.1 Your record

Your medical record belongs to you. Through Gale you can read your own chart — your conditions, your medications, your results, your visits.

Three things are true today that we are not going to dress up.

(1) There is no download button. A self-service export is not built. To get a copy of your record, write to legal@gale.care. Your clinician's practice is the custodian of the record, and Gale will help them produce it. Under 45 C.F.R. § 164.524 you have a right of access to your complete designated record set, and the practice must give it to you — generally within 30 days.

(2) There is no standards-based portable data API (for example FHIR). We are not going to claim one that does not exist. A machine-readable export through a standard API is not built.

(3) Gale's engine computes an internal risk estimate to help your care team, and it is not shown to you in the chart view today. It is never shown to your family.

How long we keep your information. Your chat messages are kept for 365 days. A care-gap signup email and a scheduling request are kept for 180 days. At that point a Firestore TTL policy deletes them — the database itself does it, rather than a scheduled job that has to remember to. Your medical record is a separate matter and is not on this schedule: federal law requires the practice to keep it for at least six years (45 CFR 164.530(j)), and longer in several states.

Deletion. Your chat messages you can delete yourself — one at a time or all at once, from your profile. A treatment record generally may not be deleted on request in any event — HIPAA gives no deletion right and state law requires practices to retain records. For the rest of the non-HIPAA consumer-health data (your screening results, your searches, a signup email), the deletion and access rights in state law reach it but no self-service control exists yet: write to legal@gale.care and we will handle it manually. We respond within 45 days. We cannot yet promise deletion from backups.

11.2 Research

Gale will conduct research to improve patient care. We would rather describe it precisely than gesture at it.

What is true today.

• The information Gale's engine retains to learn from carries no identity. It holds five things and nothing else: the area of medicine involved (for example, anxiety); a coarse measure of how severe the case was; a coarse measure of how the person responded; an age range rather than an age (the top band is 65 and older); and a region — a multi-state U.S. Census division, never your state, your city, or your ZIP code. That is what the data structure is capable of holding, not a promise about how we behave.
• And there is no link back to your visit. The signal is written and then deliberately orphaned: its identifier is not stored on the visit record and no part of Gale's software returns it. Until 13 July 2026 that was not true — Gale did write the signal's identifier back onto the visit record, which was a re-identification key, and an earlier draft of this document wrongly claimed otherwise. The key was removed rather than the claim softened, and a test now fails Gale's build if any visit record is found carrying a signal identifier. The Privacy Policy and the practice's Notice of Privacy Practices state this in the same words.
• Gale conducts no research on your information and trains no model on it — identifiable or otherwise. The Business Associate Agreement does not permit Gale to research patient information or to train on it, and we would rather fix the contract than paper over it with a consent form. One narrow permission was added to these Terms on 23 July 2026 and it is not research: de-identified, aggregated benchmarks, with structural floors, described in full in Section 11.5. There is no form in this product through which you could consent to research even if you wished to. If that ever changes, everything in the next list applies — and you would be asked, not informed.

What will be true of any identifiable research, before we do a single study.

• It requires your separately signed HIPAA Authorization under 45 C.F.R. § 164.508.
• It is its own document, signed on its own. Not in these Terms, not in the booking flow, not bundled with anything else you sign. If you are ever presented with a form that bundles research with anything else, it is not ours.
• It is revocable. You can revoke it in writing at any time, and we will stop using your identifiable information for research when we receive the revocation. HIPAA is honest about one limit and so are we: revoking does not undo research already done in reliance on it (45 C.F.R. § 164.508(b)(5)(i)). It stops everything going forward. Your Authorization form will say the same thing, in the same words.
• It is never a condition of getting care. Your clinician will treat you whether or not you sign it. HIPAA's baseline rule (45 C.F.R. § 164.508(b)(4)) already forbids conditioning treatment on an Authorization — but it carves out an exception for research-related treatment: a clinical trial may lawfully be conditioned on one. Gale waives that exception. Gale will not build, host, or transmit an Authorization that conditions any care on signing it, including research-related treatment. That is a commitment stricter than the regulation, and it is ours, not the law's.

The de-identification method Gale asserts is Safe Harbor (45 C.F.R. § 164.514(b)(2)) — the same method the Privacy Policy and the practice's Notice of Privacy Practices assert. Its separate condition — that no re-identification code be held (§ 164.514(c)) — is met as of 13 July 2026, when the back-reference described above was removed from the code.

11.3 Never for advertising. Never for marketing. Never sold.

Gale will never use your personal or health information for advertising or marketing. Gale will never sell it. Gale will never share it for cross-context behavioral advertising. There is no narrower version of this sentence anywhere in this document, and there is no form you could sign that would change it.

This promise covers de-identified information too. Gale does not sell, license, or trade de-identified information — not to a drug company, not to an insurer, not to a data broker, not to anyone. If and when the engine draws on de-identified signals to improve care, that stays inside Gale. That closes the loophole this kind of promise usually leaves open, and we are closing it on purpose.

Here is exactly what Gale does and does not collect, so you do not have to take the paragraph above on faith.

• Gale's web application contains zero third-party analytics or advertising packages. Not "we turned them off" — they are not installed. There is no Google Analytics, no Meta pixel, no advertising SDK, nothing of the kind, anywhere in the application's dependency list.
• Gale maintains an automated gate (evals/pixel_gate.py) that scans every compiled file of the built application against a deny-list of third-party tracking and advertising hosts, and that fails if an analytics package is ever added to the dependency list. We run it against our builds.
• Gale sets no advertising identifiers and no third-party cookies of any kind. The only cookie Gale sets is a first-party token that remembers which invitation link a clinician used to reach our provider sign-up page. It is deleted the moment they sign up, it never appears on a care-seeking page, and it is never used for advertising.
• Gale measures its own product with a first-party beacon, and we are going to describe it exactly. When you open a health article or start a screening tool, Gale's own server records what was opened — the article's name and care type, or the tool's name — together with a random code that identifies your browser tab and nothing else. That code is newly generated for each tab, is never linked to your name, your email, or your account, and is never a cookie. The words you type into search are never sent. A screener's answers and score are never sent. This information goes only to Gale, on Gale's own servers. It is never sent to an advertising or analytics company, because we do not use one.
• Gale does not build a profile of what you read. The "recently read" list Gale keeps for you lives in your own browser and is never uploaded.
• And the thing every website is true of, said out loud: like every website, our hosting layer receives and logs the request for each page you open — an IP address, a URL, a timestamp. Those logs exist for security and operations. They are never joined to an advertising identifier, never used for marketing, and never sold or shared for advertising.

There is no marketing authorization form on Gale, because there is nothing we would do with it.

11.4 Some of your information is protected by rules stricter than HIPAA

Records about substance-use treatment from a federally assisted program are protected by a separate federal rule (42 C.F.R. Part 2) with its own consent requirements — a HIPAA Authorization is not enough for them. Several states, Illinois among them, protect mental-health records more strictly than HIPAA does and require a separate, dated, purpose-specific written consent for each disclosure.

Where a stricter rule applies to your information, the stricter rule governs, and Gale's software follows it.

11.5 Benchmarks and network intelligence

These Terms are a permission — a narrow one. Gale may build de-identified, aggregated benchmarks from practice- and patient-derived information: cohort-level statistics across many practices, such as how quickly payers pay and how often they deny, where a practice's fees sit against the range, appointment fill and no-show patterns, and care outcomes at the level of "practices like this one" — never at the level of a person. Clinicians see them so a solo practice can know what only a network otherwise could.

The floors are structural, not promised.

• No benchmark contains identity. Not your name, not a patient list, not a visit — nothing finer than the engine-signal shape Section 11.2 describes: an age range, a multi-state Census division.
• No cell built from fewer than 25 practices is ever shown. Below that the number is suppressed — and suppressed cells stay suppressed rather than becoming derivable from what remains: the aggregation rules are built so a practice cannot subtract itself out of a small cohort to expose a competitor.
• A practice sees its own position against the cohort — never another practice's number.

The two things this permission is not.

• It is not research and it is not training. No model is trained on patient information, identifiable or de-identified. Section 11.2's posture is unchanged, and this section does not loosen it.
• It is not advertising, marketing, or sale. Section 11.3 is unqualified and stays unqualified — including for every benchmark this section permits.

12. Acceptable use

Do not:

• Impersonate another person, impersonate a clinician, or misrepresent your identity or your age.
• Misrepresent your physical location. See Section 5.3 — this one can make a lawful visit unlawful.
• Create an account for someone else without the legal authority to do so.
• Harass, threaten, or abuse a clinician, a practice's staff, or Gale's staff.
• Use Gale's care-finding or messaging features to harass, hoax, or spam a practice.
• Use content from Gale's health library to give medical advice to other people.
• Scrape, reverse engineer, decompile, circumvent a rate limit, or access Gale by automated means without our written permission.
• Upload malware, attempt to breach security, or access an account that is not yours.
• Use Gale to break the law.

We may suspend access immediately where there is a safety risk.

13. Content and intellectual property

13.1 Gale's intellectual property

Gale owns the software, the health library, the design, and the Gale marks. You get a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to use Gale for its intended purpose. Nothing else is granted.

13.2 Your content — and the narrow license you give us

You own what you put into Gale. You give Gale only the license it needs to run the service for you: to host, store, transmit, display, and process your content solely to provide the service to you and to your care team, and to create the de-identified information described in Section 11.2 — information that carries no identifier of you and cannot be turned back into you.

This license is bounded by Section 11.3, and no future version of our Privacy Policy can widen it. It is never a license to use your information for advertising or marketing, and it is never a license to sell it.

Gale does not take a perpetual, irrevocable, sublicensable license over your content. That clause is standard boilerplate in consumer terms and it has no business in a health platform.

13.3 Feedback

If you send us an idea or a suggestion about the product, we may use it freely, without obligation to you. This license covers feedback and ideas only. It expressly excludes your health information and anything in your medical record.

13.4 Copyright

Gale Care is a registered trademark of Gale Care Inc. Gale hosts no user-posted public content today, so a designated DMCA agent under 17 U.S.C. § 512 is not required. Direct any copyright or trademark concern to legal@gale.care; if Gale ever hosts user-posted content, it will register an agent and name it here.

13.5 The research papers — whose they are, and what Gale may show you

The papers behind Section 6.5 are not Gale's. Gale did not write them, does not own them, and shows them to you under the licence each author chose.

• What Gale holds is the title, the abstract, and the bibliographic details. Gale stores no PDFs, no full text, and no article packages from any source. Every row links out to the article on the site that published it, and that site is where you read the paper itself.
• Only openly licensed work is included. Gale ingests an abstract only where the article carries a CC BY or CC0 licence — the licences whose terms permit redisplay. Anything else, or anything with no licence stated, is left out rather than assumed to be fine.
• Where they come from. The National Library of Medicine's PubMed and PMC Open Access collections, and the medRxiv preprint server. Citation and abstract data are used courtesy of the National Library of Medicine; Gale is not endorsed by, affiliated with, or responsible to NLM, NIH or HHS, and NLM is not responsible for what Gale does with the data.
• Preprints are labelled as preprints. A preprint is a preliminary report that has not been certified by peer review; medRxiv's own words are that preprints "should not be relied on to guide clinical practice or health-related behaviour". Gale marks them wherever they appear, and a step in a draft plan supported only by preprints is left out of the draft.
• A licence expires when it is withdrawn. When an article leaves an open-access collection, Gale drops it on the next rebuild of the shelf rather than continuing to show it.

Nothing in this section is a licence to you beyond reading them inside Gale. Section 13.1's limited licence is what you have; the authors' own licence terms govern anything else you want to do with a paper, and the link on every row is how you reach them.

14. Third-party services and subprocessors

Gale uses third-party services to operate. The Google Cloud HIPAA Business Associate Addendum was signed on 13 July 2026, covering Google's HIPAA-eligible infrastructure and the Vertex AI model. No agreement yet covers the other vendors below, and real patient information does not flow to a vendor before the agreement covering it is signed. The Privacy Policy carries the full register; here is every class and every vendor we know of, with its status.

There is no third-party advertising or analytics vendor. There is nothing to name, because there is nothing there.

And there is no search vendor. Gale's health search and the research-paper shelf behind § 6.5 run on Gale's own servers, inside Gale's own Google Cloud project — the Google Cloud Run row above, and no other company. Your scrubbed query reaches no search vendor, and that service keeps no log of what was searched. The public research services the shelf was built from — PubMed / PMC Open Access, medRxiv — are sources, not vendors: the shelf is assembled from them ahead of time, in bulk, and they receive nothing about you, not even the fact that you searched. Section 13.5 says whose the papers are.

Today there is no video vendor. Gale's telehealth video is peer-to-peer — the media travels directly between your device and your clinician's, and passes through no Gale server and no video company's server. Two things you should still know:

• Your device and your clinician's device necessarily exchange IP addresses to connect to each other.
• To find each other, they each contact a public Google STUN server, which sees the connection attempt but never the audio or video.

And a tripwire we are setting on ourselves. Gale's software has a seam for a relay server — used when two devices cannot reach each other directly. It is off. If Gale ever turns it on, that relay carries your visit's media stream (encrypted), which makes it a subprocessor and a Business Associate: it requires a Business Associate Agreement, it gets named in the table above and in the Privacy Policy, and we will change this section before we turn it on, not after.

Your use of a third-party service is subject to that party's terms. This does not disclaim Gale's own obligations for its subcontractors under HIPAA and under its Business Associate Agreements — those obligations are Gale's and are not shifted to you.

15. Suspension and termination — and what happens to your record

Gale may suspend or terminate your access for a material breach of these Terms, where the law requires it, or where there is a safety risk. Where practicable we will give you notice and, where the breach can be cured, a chance to cure it. You may close your account at any time.

The part that matters:

• Terminating your Gale account does not end your relationship with your clinician, and it does not affect your clinician's professional obligations to you. Losing software access is not being discharged from care.
• Your medical record belongs to you. Before or after termination you may request a copy from your clinician's practice, which is the custodian of the record, and Gale will help them provide it. There is no self-service download today (see § 11.1).
• We will not use termination of your account to interfere with your access to your health information.

16. Disclaimers

PLEASE READ SECTIONS 16 AND 17 CAREFULLY. THEY LIMIT WHAT YOU CAN RECOVER FROM GALE — THOUGH NOT FOR ANYTHING TO DO WITH YOUR MEDICAL CARE, NOT FOR OUR OWN FRAUD, GROSS NEGLIGENCE, OR WILLFUL MISCONDUCT, AND NOT FOR ANY RIGHT A PRIVACY STATUTE SAYS CANNOT BE LIMITED.

In plain terms: we do not promise the software will always work, and we do not promise the health information in it is right for your particular situation.

Formally: the Gale software is provided "AS IS" AND "AS AVAILABLE." To the fullest extent permitted by law, Gale DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY (a promise that software is of ordinary, acceptable quality), FITNESS FOR A PARTICULAR PURPOSE (a promise that it suits your specific need), and NON-INFRINGEMENT, and any warranty that the software will be uninterrupted, error-free, or secure.

Gale does not warrant the clinical accuracy, completeness, or suitability of any content in its health library, symptom search, screening tools, or chat. That content is general health information, not medical advice, and is not a diagnosis.

What Gale does not disclaim. Gale does not disclaim and does not limit liability for its own fraud, willful misconduct, or gross negligence; for death or personal injury caused by its negligence; or for any liability that may not be limited or excluded under applicable law. Some states do not allow the exclusion of implied warranties or the limitation of certain damages, so some of the above may not apply to you.

17. Limitation of liability

In plain terms: this section limits what you could recover from Gale if the software harms you. It does not limit anything to do with your medical care — a claim against your clinician is not capped by this — and it does not limit the things listed in Section 16 under "What Gale does not disclaim."

To the fullest extent permitted by law, Gale will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for lost profits, lost data, or loss of goodwill, arising out of or relating to the Gale software.

Gale's total liability for all claims relating to the Gale software will not exceed the greater of (a) the amounts you paid Gale in the 12 months before the claim, or (b) $100.

These limits do not apply to:

• The matters listed under "What Gale does not disclaim" in Section 16.
• Any claim arising from medical care provided to you by a clinician or a practice. That claim is between you and them and is not limited by these Terms.
• Gale's obligations under a Business Associate Agreement or under HIPAA.
• Any claim under a consumer-privacy or medical-privacy statute that forbids limiting it. California Civil Code § 1798.192 makes void any contract term that limits rights under the CCPA/CPRA, including a representative-action waiver. Nothing in these Terms limits those rights, or the equivalent rights under the California Confidentiality of Medical Information Act, Washington's My Health My Data Act, or any similar law of your state.

18. Indemnity

Gale does not ask patients for an indemnity. There is none in this document and we are not reserving one.

If you are a practice, indemnity is negotiated in your Master Services Agreement, where it belongs and where it is actually bargained over.

19. Dispute resolution — arbitration and class-action waiver

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS.

Who this Section applies to. This Section applies to disputes between Gale and a patient or other individual user. A dispute between Gale and a practice is governed by the dispute-resolution clause of the Master Services Agreement, not by this Section.

19.1 Talk to us first

Before starting an arbitration, you and Gale agree to try to resolve the dispute informally for 60 days. Send a written Notice of Dispute — your name, your contact information, the facts, and the relief you want — to legal@gale.care. Either of us may ask for a telephone settlement conference. The 60-day period tolls any limitations period.

This does not apply to a small-claims case. Either of us can go straight to small-claims court under § 19.3(b) without waiting.

19.2 Agreement to arbitrate

Except as stated in § 19.3, you and Gale agree that any dispute arising out of or relating to these Terms or the Gale software will be resolved by binding individual arbitration, administered by the American Arbitration Association (AAA) under its consumer arbitration rules.

The arbitrator decides the merits of the dispute. A court — not the arbitrator — decides whether this Section applies at all: its formation, its scope, its validity, and its enforceability. This sentence controls over any contrary rule of the administrator, including any rule that would give the arbitrator power to rule on his or her own jurisdiction. This agreement is governed by the Federal Arbitration Act, 9 U.S.C. §§ 1–16.

19.3 What is NOT arbitrated

• (a) Sexual assault and sexual harassment. If your claim relates to a sexual assault dispute or a sexual harassment dispute as defined in 9 U.S.C. § 401, you may bring it in court, and the class-action waiver in § 19.5 does not apply to it. This right is yours to elect at your sole option, and nothing in these Terms waives it. The court, not an arbitrator, decides whether this applies, regardless of anything else in this Section. 9 U.S.C. §§ 401–402 (Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021, Pub. L. 117-90).
• (b) Small claims. Either of us may bring a qualifying individual claim in small-claims court, with no waiting period and no precondition.
• (c) Injunctive relief for infringement or misuse of intellectual property, and any claim for public injunctive relief that cannot be waived under applicable law.
• (d) Claims against your clinician or their practice. This Section is between you and Gale only. It does not cover, and Gale does not seek to arbitrate, any claim of professional negligence or malpractice against a clinician or a practice. Any arbitration agreement about your care is between you and them.
• (e) Claims a statute makes non-waivable. The class-action waiver in § 19.5 does not apply to any claim for which a representative-action waiver is void by statute — including, in California, a claim under the CCPA/CPRA (Cal. Civ. Code § 1798.192).

19.4 Your right to opt out — at any time

You may opt out of § 19.2 and § 19.5 at any time, not only in your first 30 days, by turning on the Arbitration opt-out control in your Profile settings — which records your opt-out to your account with the date and the version of these Terms — or by writing to legal@gale.care. Opting out does not affect any other part of these Terms and will not affect your access to Gale in any way. We will confirm your opt-out in writing within 10 business days and keep a durable record of it.

19.5 No class actions

Except as stated in § 19.3, you and Gale each waive the right to bring or take part in a class, collective, consolidated, or representative action. If this waiver is held unenforceable as to a particular claim, that claim, and only that claim, proceeds in court.

19.6 Fees, and where it happens

Gale pays the arbitration fees — including yours. Gale pays the filing fee, the administrator's fees, and the arbitrator's fees, including any portion the administrator's consumer rules would otherwise charge you. You pay nothing to start an arbitration against us.

The arbitration proceeds by document submission or by telephone or video unless the arbitrator orders otherwise. Any in-person hearing takes place in the county where you live, or somewhere else we both agree to.

19.7 Changes and severability

If Gale materially changes this Section, the change does not apply to any dispute Gale already had notice of on the effective date, and you may reject the change by emailing legal@gale.care. If any part of this Section is unenforceable, the rest stays in effect, except as § 19.5 provides.

19.8 Governing law

These Terms are governed by the law of the State of California, without regard to its conflict-of-laws rules. If the arbitration agreement in this Section is held unenforceable, the exclusive venue is the state and federal courts located in San Francisco, California — subject always to the mandatory-law protection stated below.

Nothing in this Section deprives you of the protection of the mandatory laws of the state where you live. A choice-of-law clause cannot waive your home state's non-waivable consumer protections.

20. Electronic records and signatures

How you give this consent. During sign-up we show you this disclosure as a PDF and ask you to confirm that you can open it. Confirming is what gives the consent — and it is also how the law asks us to check that you can actually read what we will send you (15 U.S.C. § 7001(c)(1)(C)(ii)). If you cannot open it, tell us and we will send you everything on paper, at no charge.

When you confirm this disclosure during sign-up, you consent to receive from Gale — electronically, on the Gale website or app or by email — these Terms, our Privacy Policy, and all notices, agreements, disclosures, receipts, and records related to your use of Gale. This consent applies to all such records, not just to one transaction.

• You have the right to a paper copy. Ask us at legal@gale.care (postal: Gale Care Inc., c/o Legalinc Corporate Services Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA) and we will provide one at no charge.
• You may withdraw this consent at any time, at no charge, by writing to legal@gale.care. Withdrawing means we can no longer provide you the Gale software online and you may need to close your account. Withdrawing does not affect the validity of anything done before you withdrew.
• To access and keep these records you need: a current web browser (a recent version of Chrome, Safari, Edge, or Firefox), an internet connection, a device that can display PDF files, and a working email address. If those requirements change in a way that creates a material risk you cannot access or keep your records, we will tell you and you may withdraw consent with no fee and no condition we did not disclose.
• Keep your email address current in your account settings.
• Electronic signatures. Clicking "I agree," typing your name, or a similar act is your signature — legally the same as signing on paper.

This disclosure is given under the federal ESIGN Act, 15 U.S.C. § 7001, and specifically the consumer-consent requirements at 15 U.S.C. § 7001(c), together with your state's Uniform Electronic Transactions Act (or, in New York, its Electronic Signatures and Records Act).

21. Changes to these Terms

We may update these Terms. When we do:

• We will post the new version with a new effective date and keep the old versions available.
• For a material change we will give you notice by email and in the product, and we will ask you to accept the change rather than deem your silence to be acceptance.
• A material change to Section 19 (Dispute resolution) always requires a fresh acceptance.
• No future version of these Terms or of our Privacy Policy may narrow Section 11.3.

Continued use after a non-material change means you accept it.

22. General

Assignment. Gale may assign these Terms to an affiliate or in connection with a merger, an acquisition, or a sale of assets. You may not assign them. In any such transaction, any successor is bound by the same commitments and the same Privacy Policy; protected health information transfers only as HIPAA permits and only to a successor that assumes the Business Associate Agreement; and we will tell you about a change of control that materially affects how your information is handled. The commitments in Section 11.3 — never for advertising, never for marketing, never sold — bind any successor.

Force majeure. Neither party is liable for a delay caused by something outside its reasonable control: acts of God, war, terrorism, pandemic, government action, a utility, telecom, or cloud-provider failure, or a labor dispute. This does not excuse Gale's data-security obligations or its breach-notification obligations, which are not suspended by an outage.

Severability. If a provision is unenforceable, the rest stands.

Survival. The following survive termination: Section 10 (amounts already owed), Section 11 (health information), Section 12 (acceptable use), Section 13 (intellectual property), Section 16 (disclaimers), Section 17 (limitation of liability), Section 19 (dispute resolution), Section 20 (electronic records), this Section 22, and — for a practice — Appendix B, § B.2 (HIPAA).

Entire agreement. These Terms, the Privacy Policy, and — for a practice — the Master Services Agreement and the Business Associate Agreement are the whole agreement between us about the Gale software. They do not displace any agreement you have with your clinician.

Notices. To you: by email to the address on file, plus in-product notice for a material change. To Gale: Gale Care Inc., c/o Legalinc Corporate Services Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA, and legal@gale.care.

No waiver. If we do not enforce a provision, we have not waived it.

23. How to reach us

Gale Care Inc. is a Delaware corporation. Registered address: c/o Legalinc Corporate Services Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA.

A question about your care goes to your clinician, not to us. We cannot answer it and it would be wrong of us to try.

Appendix A — Definitions

• The Gale software. The website at gale.care, the Gale mobile applications, the patient portal, the health library, symptom search, the screening tools, the chat, the care-finding tools, and the practice-facing software described in Appendix B — and nothing else. It does not include medical care, which is provided by a clinician and their practice.
• You. The person using Gale — a patient, a person acting for a patient they have legal authority for, a clinician, a practice's staff member, or anyone else who creates a Gale account or uses Gale's public surfaces.
• Business Associate. A person or company that creates, receives, maintains, or transmits protected health information on behalf of a Covered Entity. Gale is a Business Associate.
• Covered Entity. Under HIPAA, a health plan, a health-care clearinghouse, or a health-care provider that transmits health information electronically in connection with a covered transaction. Your clinician's practice is the Covered Entity. Gale is not.
• Consumer health data. Personal information that identifies a person's past, present, or future physical or mental health status — including the fact that they are seeking health care — and that is not protected health information and is not intermingled with protected health information. It is governed by state consumer-health-data law, not by HIPAA. Gale's public surfaces produce it.
• De-identified. Health information that does not identify a person and for which there is no reasonable basis to believe it can be used to identify one, established by one of the two methods HIPAA allows — Expert Determination or Safe Harbor (45 C.F.R. § 164.514(b)). Gale asserts Safe Harbor. Safe Harbor also forbids holding a re-identification code (§ 164.514(c)); Gale held one until 13 July 2026, when it was removed — the engine no longer writes the signal's id back beside the patient's record, and a test fails the build if it reappears. See § 11.2. "Carries no patient identifier" is not by itself the HIPAA test, which is why the code had to go rather than merely be left unused.
• HIPAA Authorization. A signed, revocable permission under 45 C.F.R. § 164.508 to use or disclose identifiable health information for a purpose HIPAA does not otherwise allow — for example, identifiable research. Never a condition of receiving care on Gale.
• Practice. The licensed professional entity through which your clinician practices. It owns the medical record and is responsible for your care.
• Protected health information (PHI). Individually identifiable health information held or transmitted by a Covered Entity or its Business Associate.

Appendix B — Terms for providers and practices

This appendix applies to you if you are a clinician, a practice, or a practice's staff. It is part of these Terms and it binds you.

If you are a patient, this appendix is not yours. Sections 0–23 are your terms. You may read this — it tells you what we promise your clinician — but it does not bind you.

Your practice's full commercial relationship with Gale lives in a separate Master Services Agreement and a separate Business Associate Agreement. Where those documents and this appendix conflict, those documents control. This appendix states the terms that are true across all of them.

B.1 You practice medicine. Gale does not.

You exercise independent professional judgment. Gale does not direct your clinical decisions, does not set your clinical protocols, does not set your clinical fees, does not control your clinical staffing, and does not hold your professional fee. You are responsible for the care you provide, for the content of your notes, and for the accuracy of every claim submitted in your name.

Practice-management automation in Gale is administrative only. Where Gale produces something that recommends a clinical action, a named licensed clinician owns that decision, and Gale shows you the basis for it. Gale will not send a patient a communication conveying a clinical status change unless a licensed clinician owns that action.

B.2 HIPAA — you are the Covered Entity; Gale is your Business Associate

Your practice is the Covered Entity. Gale is your Business Associate. Gale creates, receives, maintains, and transmits protected health information on your behalf under a written Business Associate Agreement, as required by 45 C.F.R. §§ 164.502(e) and 164.504(e). Gale's subcontractors that touch PHI are bound by the same obligations, as 45 C.F.R. § 164.502(e)(1)(ii) requires.

No PHI may be processed through Gale until the BAA is signed and until Gale's own upstream Business Associate Agreements are in place. Today they are not, and Gale's software refuses real PHI at the gate.

B.3 Licensing and credentialing — Gale never auto-attests

Gale automates the paperwork of getting you licensed and credentialed — NPI, multi-state licensing, CAQH, DEA, per-payer credentialing, with honest lead times.

Gale will never auto-attest, auto-sign, or pre-fill a credential status as fact on your behalf. Attestation is your own legal act. A false attestation exposes you to board discipline and to fraud liability. Gale will prepare, organize, and submit; you attest. This is not a product limitation we intend to remove.

You are responsible for maintaining your licenses, your DEA registration where applicable, and your malpractice coverage, and for telling Gale promptly if any of them lapses, is restricted, or is under investigation.

B.4 Your record, your claims, your note

The medical record is your practice's. Gale's scribe produces a draft. You read it, you edit it, you sign it. Your edit is the record, and Gale treats your edit as the ground truth. Gale does not alter a signed note.

You are responsible for the content of every claim submitted under your NPI. Gale prepares and transmits; you are the biller of record for what the claim says.

B.5 The platform fee — stated exactly as the code computes it

Gale's fee is one flat all-in rate: 3.5% of each paid transaction, on every rail — cash or insurance, any patient — card clearing included, so there is no separate billing-cost line. On a $200 paid transaction the fee is $7.00; on a $400 paid transaction it is $14.00. This schedule is in effect. In New York and Texas the percentage is replaced entirely by the fixed-fee schedule described below, because those states' fee-splitting law reaches percentage-based fees. Counsel reviews this production instance's fee configuration (founder direction, 2026-07-18).

Where no fee-schedule document is set for a state, the software's built-in default applies: a fixed billing cost of $2.50 per paid transaction plus 15% of the transaction amount. We state that default exactly because that is what the code computes absent a schedule document, and an earlier draft of this document described it in a way the arithmetic does not support. On a $200 paid transaction the default fee is $32.50; on a $400 paid transaction it is $62.50. The 15% term is applied to the transaction amount, so that fee does scale with the size of the transaction. Read the review note below before you rely on any characterization of either schedule.

What is true about the fee:

• It is charged to the practice, never to the patient.
• It is transparent on every transaction. Every payout ledger entry carries the fee, the percentage, the billing cost, the fee schedule it came from, and the fee basis — so you can reconcile it against the schedule that produced it.
• It is not contingent on any referral and is not payment for a referral.
• It applies only when a transaction is paid. Gale does not charge a fee on an unpaid claim.
• One optional add-on. If you opt in to instant payout ("get paid now"), Stripe charges 1% of the payout amount to move the money in minutes. Gale passes that cost straight through to you, itemized on the payout row, and adds nothing to it. It is optional and off by default; standard payouts carry no such fee.
• One rate, no origination tiers. The ratified flat fee is the same 3.5% whether the patient found you through Gale or was already yours, and the same on a self-pay session, an insured copay, and a payer payment. The prior 8%/3.5%/6% origination-tiered cash schedule (ratified 2026-07-10) is superseded; origination is still recorded on payout rows for audit, but it no longer changes the price.
• The strict-state schedule (New York and Texas — in effect). In states whose fee-splitting law reaches any percentage of a licensee's receipts, the percentage is replaced entirely: Gale's compensation is a fixed $1.00 per paid transaction, and third-party transaction costs (card processing, clearinghouse) are passed through at cost and itemized separately on the payout row — the only percentage on the row is a third party's charge, never Gale's. No percentage model applies in those states.

[UNDER COUNSEL REVIEW — on the production instance (founder direction, 2026-07-18)] A percentage fee is dependent on the licensee's receipts, and strict-state fee-splitting law reaches exactly that: N.Y. Educ. Law § 6530(19) expressly reaches compensation that "constitutes a percentage of, or is otherwise dependent upon, the income or receipts of the licensee." That is why no percentage model applies in New York or Texas — those schedules carry the fixed $1.00 + at-cost pass-through structure, whose only percentage is a third party's own charge. The flat 3.5% elsewhere is a percentage of collections on its face, and the built-in default's 15% term is applied to the transaction amount — the sentence "it is not a share of your collections" was removed from this document because it was not true. Counsel reviews this production configuration per state; real dollars are additionally governed by the platform's live-money switch and the Stripe account controls.

B.6 How money moves

• Gale never controls your money as its own, and never keeps your professional fee. But we are going to be precise about the mechanics, because an earlier draft was not. Gale uses Stripe destination charges on Express connected accounts: the charge is created on Gale's Stripe platform account, and your net — the transaction amount minus Gale's fee — is then transferred to your practice's own Stripe Connect account. The funds transit Gale's platform balance. Gale is, on that flow, the merchant of record. See the counsel block in Section 10.
• Who gets paid depends on the rail. On private-pay and commercial-insurance claims, the money goes to your practice's Stripe Connect account as described above. On a school-linked claim billed through a school district's existing Medi-Cal enrollment, the district is the enrolled biller and receives the reimbursement directly — it never passes through Gale, and it does not land in your Stripe account; your practice is paid by the district under your agreement with it, and Gale posts only its fee row.
• Gale never advances funds ahead of payer payment. That is absolute and it holds on every rail: Gale does not front you cash from its own balance sheet, ever. If any acceleration product is ever offered, it will run through a separately approved, regulated partner, never Gale's balance sheet.
• "Fast" means different things on different rails, and we will not blur that. On a commercial or private-pay claim, a clean claim plus an instant Stripe payout is the design target. On a school-linked Medi-Cal claim billed through a district's enrollment, payment is structurally slow — interim payments reconciled annually to actual cost — and no software makes that fast. Gale has no observed payout data yet. Every timing figure Gale publishes is an estimate, labeled as one, until real claims produce real numbers.
• Clinical detail never enters the payment payload. See Section 10.

B.7 Your directory listing

Gale builds a public provider directory from the NPPES public registry — a clinician's name, NPI, specialty, and city/state. These are public facts from a public federal registry. Gale does not publish license numbers, street addresses, or any Gale-computed score in that directory. If you want your listing removed, there is a removal path. Write to legal@gale.care; we tombstone your NPI so it is not re-published on a later data refresh, and confirm when it is done.

Separately: Gale contacts clinicians about Gale. To do that, Gale uses public-registry data and professional-contact-enrichment vendors (SignalHire, PhantomBuster — see Section 14). That is B2B data about you as a professional. It is never patient data, it is never used for anything but reaching you about Gale, and you can tell us to stop at legal@gale.care.

B.8 Suspension and termination (practices)

Either party may terminate as the Master Services Agreement provides. Terminating Gale does not terminate your relationship with your patients, and it does not relieve you of your professional obligations to them. On termination, Gale will provide your practice its data in a usable form and will not use its access to your records to interfere with your patients' access to their health information. Gale provides your practice's data in a standard, machine-readable format (CSV or JSON) within 30 days of a written request, at no charge.

B.9 Connecting an AI assistant to your practice

Gale can connect your practice to an AI assistant of your own choosing — Claude.ai today, ChatGPT as a named next step — over a standard protocol (Model Context Protocol, MCP). This is optional, off by default, and you can revoke it at any time from Settings → Connected AI; revocation is immediate.

The rails, stated as terms, not just as product copy:

• The connection can read and write your own practice-configuration data — services, rates, hours, payer targets. It cannot move money, submit a claim, sign or attest anything, or reach a patient record — those actions do not exist on this connection, at all, for any tool it exposes.
• What leaves Gale over this connection is structured, typed business fields only. Free text about a person has no path onto it; a tool call carrying anything else is rejected before it is stored.
• The AI assistant you connect is not a Gale subprocessor and is not covered by Gale's Business Associate Agreement obligations. It is a tool you selected, operated by its own maker (Anthropic for Claude.ai; OpenAI once ChatGPT ships), and what you say to it and what it does with that is governed by that maker's own terms, not these Terms. Read that vendor's terms before you connect it.
• The data this connection carries is your own business configuration — not a patient record — so no PHI crosses it and no BAA question arises on this rail. If Gale ever lets this connection touch anything besides your own business configuration, that is a new feature requiring its own disclosure, not a silent expansion of this one.

Appendix C — Version history

Related documents

• Privacy Policy — incorporated into these Terms. The complete account of what Gale collects, where it goes, and the three commitments that cannot be amended.
• Consumer Health Data Privacy Policy — the standalone Washington My Health My Data policy governing what you generate as a visitor: the chat, screeners, searches, and the care front door.
• Notice of Privacy Practices — issued by your clinician's practice, which is the Covered Entity for your medical record. Not Gale's, and Gale cannot issue one.