How Figment SimCare collects, uses, and protects your information.
Palmetto Innovative Education, LLC ("Figment," "we," "our," or "us") operates Figment SimCare: an iPad app for clinical simulation training and a companion web platform at figmentprograms.com for instructors and administrators (collectively, the "Service").
This Privacy Policy describes what information the Service collects, what stays on your device, what is sent to our servers and to third-party processors, and your choices and rights. By using the Service, you agree to the practices described here.
The app records the following, associated with your access code:
The mapping between an access code and a particular student, if one exists at all, is held by the issuing instructor or institution, in their own systems, outside the Service. We cannot connect a session to a named person.
Stored on your iPad only, never sent to us: your choice of Communication Coach framework, whether attention tracking and the zone overlay are on, and your acknowledgement of the AI disclosure shown on first launch.
Instructors and institutional administrators do have accounts, and signing in is how they reach their own cases, codes, and rosters, whether they sign in on the web at figmentprograms.com or in the iPad app. For an account holder we collect:
Instructor account details are never transmitted to OpenAI, ElevenLabs, or any other AI service, a request to generate a reply or a voice carries the conversation text and nothing that identifies who is having it. Nor is an instructor's identity ever attached to a student's session: student work is recorded against an access code and cannot be traced back to a person by us. The reverse does apply to an instructor's own test runs, which are deliberately saved to their account so they can find them again.
Our servers record an IP address and a timestamp for every request, including requests made by the iPad app, for security and abuse prevention. For a signed-in instructor these sit alongside the account. For a learner on an access code there is nothing to attach them to beyond the code itself. Logs are not used for analytics, profiling, advertising, or any purpose other than keeping the Service secure.
| Feature | Where it runs | What is sent off-device |
|---|---|---|
| Patient dialogue | OpenAI, via our server | Your message and the conversation so far for that case |
| Patient voice | ElevenLabs, via our server | The character's spoken line only, never your words |
| Speech-to-text (dictation) | Apple Speech framework, on-device | Nothing on supported iPads. On older hardware without on-device support, Apple's Speech framework may process short audio segments server-side under Apple's own privacy policy; the app indicates when this applies |
| Communication Coach | Apple Foundation Models, on-device | Nothing. The feedback is written on the iPad and is never transmitted. The exchange it reads has separately gone to OpenAI to produce the character's reply |
| Attention (eye) tracking, optional | ARKit, on-device | Nothing. Gaze is resolved to five on-screen regions; no image, video, depth map, or face template is created or stored |
| Post-visit evaluation and debriefing | OpenAI, via our server | The session transcript |
| Session storage, student | Our server | Transcript, quiz performance, and debriefing, stored against the access code only |
| Session storage, instructor test run | Our server | The same session data, stored against the instructor's own account and therefore linked to their name and email |
| Saved PDFs (transcripts, certificates) | Our server | Generated on the server, stored against whichever of the two the session belonged to |
The iPad app requests these permissions only when needed and explains why at the prompt:
You can revoke any of these permissions at any time in Settings → Privacy & Security → Microphone / Camera / Speech Recognition. The app continues to function without them, you can complete an entire interview by typing, with no microphone, no camera, and no speech recognition.
The optional attention-tracking feature uses Apple's ARKit framework to read face-mesh and eye-direction data from the TrueDepth front camera. Under Apple's App Store Review framework (Guideline 5.1.2(i)), this is biometric-related data, the anonymous geometry of your face, not a biometric identifier. We make the following commitments about its handling:
We do not sell or rent personal data. We share data only in these situations:
| Data Type | Where | Retention |
|---|---|---|
| Local session transcripts & PDFs | iPad device | Until you delete them in the app or uninstall the app |
| License activations | Server | Until the access code expires + 1 year |
| OpenAI fallback transcripts | Not stored on our servers | OpenAI retention governed by their API policy (typically 30 days for abuse monitoring) |
| Web account information | Server | Duration of account + 1 year after closure |
| Authored cases and uploaded media | Server | Until you delete the case or your account |
| Server access logs | Server | 90 days |
| Billing records | Server (and Stripe) | 7 years (legal/tax requirement) |
Because we hold no identifier for a student, we cannot locate one person's sessions on request, only the institution that issued the code knows whose it was. Deletion is therefore requested through the issuing instructor or institution, who can ask us to delete everything tied to a given access code or batch of codes. We complete such requests within 30 days.
Uninstalling the app removes the preferences stored on the iPad, your Communication Coach framework, your attention-tracking setting, and your acknowledgement of the AI disclosure. It does not delete session data, which is held on our servers.
To delete your figmentprograms.com account and all associated server-side data (account profile, authored cases, code-ownership records, any test encounters you ran yourself, and purchase history other than what we are legally required to retain for tax purposes), email info@figmenthealth.com from the address on file. We will confirm receipt within 5 business days and complete deletion within 30 days. After deletion you will receive an email confirmation.
Note: deleting your web account does not deactivate access codes already redeemed by learners; those continue to function until they expire.
Figment SimCare is intended for adult learners (18 and older) in accredited educational programs and continuing professional education. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact info@figmenthealth.com and we will delete it promptly.
Depending on your location and applicable law (including GDPR in the EEA/UK and CCPA/CPRA in California), you may have the right to: access the personal data we hold about you, correct inaccuracies, request deletion, object to or restrict processing, and receive a portable copy. To exercise these rights, contact info@figmenthealth.com. We will respond within 30 days.
California residents: we do not sell or share personal information for cross-context behavioral advertising as those terms are defined under the CCPA/CPRA. We do not offer financial incentives in exchange for personal information.
The web platform uses a single first-party session cookie (FIGMENT_SESS) for authentication. We do not use advertising trackers, third-party analytics cookies, or social media pixels. Disabling cookies will prevent web login. The iPad app does not use cookies.
We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be announced in-app or by email to active web account holders before they take effect.
Privacy questions: info@figmenthealth.com
Mailing address: Palmetto Innovative Education, LLC · Charleston, South Carolina, United States
This End User License Agreement ("EULA" or "Agreement") is a legally binding contract between you and Palmetto Innovative Education, LLC ("Figment," "we," "us"). By installing, redeeming an access code for, or otherwise using the Figment SimCare iPad app or the companion web platform at figmentprograms.com (collectively, the "Service"), you agree to be bound by this Agreement. If you do not agree, do not use the Service.
If you are using the Service on behalf of an institution, you represent that you have authority to bind that institution to this Agreement.
Subject to your compliance with this Agreement, Figment grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to use the Service for lawful educational, training, and professional development purposes. All rights not expressly granted are reserved by Figment.
The Service is provided for use by adult learners and educators. It is not a substitute for clinical supervision, licensed medical advice, or formal credentialing. AI-generated dialogue and evaluations are educational tools only.
The following terms apply to your use of the Figment SimCare iPad app (the "App") that you obtained from the Apple App Store. These terms are in addition to, and prevail over any conflicting language in, the rest of this Agreement.
You and Figment acknowledge that this EULA is concluded between you and Figment only, and not with Apple Inc. ("Apple"). Figment, not Apple, is solely responsible for the App and its content. This EULA may not provide for usage rules for Apple-licensed applications that are in conflict with the Apple Media Services Terms and Conditions as of the effective date of this EULA (which you acknowledge you have had the opportunity to review).
The license granted to you for the App is limited to a non-transferable license to use the App on any Apple-branded products that you own or control and as permitted by the Usage Rules set forth in the Apple Media Services Terms and Conditions, except that the App may be accessed and used by other accounts associated with you via Family Sharing or volume purchasing.
Figment is solely responsible for providing any maintenance and support services with respect to the App, as specified in this EULA, or as required under applicable law. You and Figment acknowledge that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the App.
Figment is solely responsible for any product warranties, whether express or implied by law, to the extent not effectively disclaimed. In the event of any failure of the App to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the App (if any) to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the App, and any other claims, losses, liabilities, damages, costs or expenses attributable to any failure to conform to any warranty will be Figment's sole responsibility.
You and Figment acknowledge that Figment, not Apple, is responsible for addressing any claims by you or any third party relating to the App or your possession and/or use of the App, including, but not limited to: (i) product liability claims; (ii) any claim that the App fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection, privacy, or similar legislation.
You and Figment acknowledge that, in the event of any third-party claim that the App or your possession and use of the App infringes that third party's intellectual property rights, Figment, not Apple, will be solely responsible for the investigation, defense, settlement, and discharge of any such intellectual property infringement claim.
You represent and warrant that (i) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a "terrorist supporting" country; and (ii) you are not listed on any U.S. Government list of prohibited or restricted parties.
Any questions, complaints, or claims with respect to the App should be directed to:
Palmetto Innovative Education, LLC
Charleston, South Carolina, United States
info@figmenthealth.com
You agree to comply with any applicable third-party terms when using the App (for example, you must not be in violation of your wireless data service agreement when using the App).
You and Figment acknowledge and agree that Apple, and Apple's subsidiaries, are third-party beneficiaries of this EULA, and that, upon your acceptance of the terms and conditions of this EULA, Apple will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third-party beneficiary thereof.
You must provide accurate registration information for any web account. You are responsible for maintaining the confidentiality of your credentials and for all activity under your account; notify us immediately of any unauthorized access at info@figmenthealth.com.
Access codes:
You agree not to:
You retain ownership of cases, characters, scenarios, quiz questions, and rubrics you create ("User Content"). By creating and publishing User Content on the Service, you grant Figment a limited, non-exclusive, royalty-free, worldwide license to host, display, and process that content solely to deliver the Service to you and authorized learners. You represent that your User Content does not infringe third-party intellectual property rights, violate applicable law, or contain personally identifiable information about real individuals without consent.
The Service, including its software, AI integrations, user interface, design, default cases, evaluation frameworks, and the names "Figment SimCare," "Palmetto Innovative Education," and associated logos, is owned by Palmetto Innovative Education, LLC and is protected by copyright, trademark, and other laws. Except for the limited license expressly granted above, no rights are transferred to you.
The Service uses large-language-model AI to generate patient dialogue and post-visit evaluations. Patient dialogue and evaluation are generated by OpenAI, and the character's voice by ElevenLabs, both through our server. The Communication Coach runs on Apple's on-device model: it reads the exchange and writes its feedback on the iPad, and that feedback is never transmitted. The exchange itself has already gone to OpenAI to generate the character's reply. You acknowledge that:
Seats and authoring subscriptions are purchased on the web at figmentprograms.com. Payment is processed by Stripe under their terms. Access codes and authoring subscriptions are non-refundable after redemption or activation. If you believe a charge was made in error, contact info@figmenthealth.com within 30 days.
The iPad app itself does not contain in-app purchases through the Apple App Store; access is granted by entering an access code obtained from your institution or the web store.
We may suspend or terminate your access for material breach of this Agreement, fraudulent activity, or non-payment, with notice appropriate to the severity of the violation. Upon termination, your right to use the Service ceases. Provisions relating to intellectual property, warranty disclaimers, limitation of liability, indemnification, and governing law survive termination.
THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED OR ERROR-FREE OR THAT AI OUTPUTS WILL BE ACCURATE, RELIABLE, OR FIT FOR ANY PARTICULAR PURPOSE.
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL FIGMENT, ITS OFFICERS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, DATA, OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE, REGARDLESS OF THE THEORY OF LIABILITY. FIGMENT'S TOTAL CUMULATIVE LIABILITY FOR ANY CLAIM ARISING FROM OR RELATING TO THE SERVICE WILL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID FIGMENT IN THE 12 MONTHS PRECEDING THE CLAIM OR (B) ONE HUNDRED U.S. DOLLARS ($100).
You agree to comply with all U.S. and foreign export control laws and regulations applicable to the Service. The Service may not be exported, re-exported, or transferred to any country or person subject to U.S. economic sanctions or to any party on a U.S. Government denied-party list.
This Agreement is governed by the laws of the State of South Carolina, without regard to conflict-of-law principles. Any dispute arising from this Agreement will be resolved by binding arbitration in Charleston, South Carolina, under the rules of the American Arbitration Association, except that either party may seek injunctive relief in any court of competent jurisdiction for intellectual property violations. You waive any right to a jury trial and to participate in any class action or class-wide arbitration.
Legal questions: info@figmenthealth.com
Support: info@figmenthealth.com
Figment SimCare is built so that learner activity stays on the iPad by default and only the minimum data needed to deliver the Service crosses the network. This page describes the safeguards in place on both the iPad app and the companion web platform.
UserDefaults or plain files.When you activate an access code on an iPad, the server issues a signed JWT containing the code id, the device id, the issued-at and expires-at timestamps. The token is stored in iOS Keychain. The signature uses an HMAC secret kept on the server and is re-verified on the server for any gated endpoint (e.g., premium TTS); the iPad app may also validate the signature locally for fast denial of expired tokens. Tokens cannot be moved between devices because the device id is part of the signed payload.
Conversation text and evaluation requests are sent over TLS to OpenAI through our server-side proxy, and the character's lines to ElevenLabs to synthesise its voice. No account name, email address, student identifier, or access code is included in either request. The Communication Coach and voice dictation run on Apple's on-device models. The coaching feedback the model writes is never transmitted, and the audio of your voice is never recorded or transmitted. This does not make the conversation private from OpenAI: the same words were sent there to generate the character's reply. Our use of the OpenAI API is governed by the standard OpenAI API Data Usage policy under which:
Stripe handles payments under PCI-DSS; we do not see, store, or transmit card numbers.
If we discover or are notified of a security incident involving personal data, we will:
We do not currently run a paid bug-bounty program but will publicly acknowledge researchers who report valid vulnerabilities (with permission).
We design Figment SimCare to be usable by as many learners as possible, including those who use Apple's built-in accessibility features. We aim to meet WCAG 2.1 Level AA on the web and to follow Apple's Human Interface Guidelines for Accessibility in the iPad app. Accessibility is an ongoing program, not a one-time check; we welcome feedback at info@figmenthealth.com.
The Figment SimCare iPad app supports Apple's standard accessibility features:
<label> elements; error messages are programmatically associated with their fieldsSeveral features are off-by-default or learner-controlled so they don't interfere with assistive technology:
If you encounter an accessibility barrier or have a suggestion, please email info@figmenthealth.com. Include the screen or page, the assistive technology you are using, and a description of what didn't work. We will respond within 5 business days.
Figment SimCare runs natively on iPad. The companion web platform at figmentprograms.com is used for case authoring, license redemption administration, and store purchases.
By default, the App uses Apple Foundation Models on-device for the patient dialogue, the post-visit evaluator, and communication scoring. This requires an Apple-Intelligence-capable iPad. If Apple Intelligence is not available on your device, the splash screen will show the reason and the App will route AI requests to OpenAI through our server-side proxy instead. You can also toggle this at any time in the in-session settings strip.
| Action | Bandwidth | Notes |
|---|---|---|
| License activation (one-time) | ~0.5 Mbps | ~5 KB request, ~1 KB response |
| First-time case download | ~3 Mbps | Includes avatar GIFs (~1–4 MB per character) |
| On-device-only interview | None after launch | Apple Foundation Models run locally |
| OpenAI fallback turn | ~1 Mbps per response | Small JSON payloads |
| Premium TTS audio | ~3–5 Mbps streaming | MP3 from OpenAI |
Firewall note: the App needs outbound HTTPS to figmentprograms.com (and, when premium TTS or OpenAI fallback is in use, the App's network calls still terminate at our domain, the OpenAI call is server-side from our proxy).
This means the on-device model couldn't be initialized, typically because your iPad doesn't support Apple Intelligence, the system is downloading the model, Apple Intelligence is disabled in Settings, or the device is in Low Power mode.
AI dialogue is probabilistic and occasionally produces unexpected replies. To improve quality:
If you encounter a reply that is unsafe or inappropriate, report it with your session id to info@figmenthealth.com.
Sessions are saved to our servers as you work, so a session is not lost if the app closes. To find one:
For technical support: info@figmenthealth.com
For billing: info@figmenthealth.com
For accessibility: info@figmenthealth.com
When submitting a request, please include: your iPad model and iPadOS version, the App version, your access code (or institution), the Session ID if applicable, and a clear description of the issue including any error text on screen.