Legal
Consumer health data privacy policy
How we handle information about a person's health. Effective September 8, 2026.
Why this policy exists
Washington's My Health My Data Act and Nevada's consumer health data law require a separate notice about "consumer health data": information that identifies a person's past, present or future physical or mental health. Trexo Theo is a medical device, so almost everything we learn about the person who will use it is consumer health data. This policy applies to residents of Washington and Nevada and to anyone whose health data we collect while they are in those states. We apply it to everyone in the United States.
It supplements our Privacy Policy. Where the two overlap, this policy controls for consumer health data.
Clinical assessment and product support
Your child’s treating therapist conducts the assessment and makes clinical recommendations. Trexo may support that process with product information, training materials, or participation in discussions. For adult users, their treating therapist conducts the assessment. The therapist’s clinical assessment does not, by itself, give Trexo access to the therapist’s clinical records.
Consumer health data we collect
- Health information contained in the prescription or letter of medical necessity supplied for the US program.
- Health information you provide in communications with Trexo, including product-support discussions.
- Device usage data recorded by a Trexo Theo in use: sessions, steps, speed, assistance settings, duration and error events.
- On this website, only the fit check result (fit, conversation, or sizing), which is derived from health-related answers. The individual answers stay in your browser.
Where it comes from
- You (parent, guardian, caregiver or adult user), through our forms, calls and messages.
- The user’s care team, through the prescription or letter of medical necessity supplied for the US program and information provided to Trexo in product-support discussions. This does not mean Trexo receives the care team’s full clinical assessment or records.
- The Trexo Theo device and companion tablet during use.
Why we collect it
- To support the treating therapist’s assessment with product information and training materials, and to use information provided to Trexo for product sizing and configuration. The treating therapist makes the clinical recommendations.
- To obtain the prescription or medical clearance the device requires.
- To deliver, set up, support, maintain and repair the device and train the people who operate it.
- To monitor safety and performance, investigate complaints and incidents, and meet our obligations as a medical device manufacturer, including reporting to the U.S. Food and Drug Administration where required.
- To produce de-identified and aggregated data for clinical research, safety and quality analysis, product and algorithm development, and outcome reporting.
- To comply with law.
We do not use consumer health data for advertising, and we do not sell it.
Who we share it with
- Service providers that process data on our behalf: hosting, customer relationship management, forms, scheduling, e-signature, training, video calling, telephony and messaging, and professional services. They may use the data only to provide services to us.
- The user’s care team. Product-support discussions with the treating therapist may involve information you or the therapist provide to Trexo. The therapist’s involvement does not give Trexo or other clinics blanket access to clinical records.
- Insurers and funding organizations, only if you ask us to help with coverage.
- Regulators, including the FDA, when medical device rules require it, and courts or law enforcement when required by law.
- Research partners (clinics, hospitals, academic institutions), in de-identified or aggregated form only.
- A successor business, if Trexo is involved in a merger, acquisition, financing, reorganization or sale of assets.
We do not sell consumer health data, and we will not do so without your separate, signed authorization as the law requires. We do not disclose consumer health data to advertisers.
Your rights
You have the right to:
- Access the consumer health data we hold about you or the user you are responsible for, and learn who we have shared it with and how to contact them.
- Withdraw consent to our collection and sharing of consumer health data.
- Delete consumer health data, including from our service providers, subject to record-keeping obligations that apply to medical device manufacturers and to payment records.
- Appeal a decision we make about your request.
To exercise a right, email privacy@trexorobotics.com or call (844) 844-0607. We will verify your identity using the contact details we hold. A parent or legal guardian may act for a child, and an authorized agent may act for you with your written permission. We respond within 45 days and will tell you if we need up to 45 more. If we decline a request, you may appeal by replying to our decision. We will respond to the appeal within 45 days and tell you how to contact the Washington or Nevada Attorney General if you disagree with the outcome.
Withdrawing consent or requesting deletion may mean we cannot provide or support a device.
How long we keep it
Prescription or letter of medical necessity, other health information actually provided to Trexo, and device records are kept for as long as needed to support the device and meet applicable record-keeping obligations. This does not describe the treating therapist’s retention of their own clinical records. Fit check results and inquiry information that do not lead to a customer relationship are deleted within 24 months of the last contact. Everything else follows the retention section of our Privacy Policy.
How we protect it
Consumer health data held by Trexo is protected as described in the security section of our Privacy Policy. Trexo’s role is product support, not the provision of the treating therapist’s clinical care.
Contact
Trexo Robotics Holdings, Inc.
440 N Barranca Ave #1001
Covina, CA 91723, United States