Consumer Health Data Privacy Policy

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CONSUMER HEALTH DATA PRIVACY POLICY

Last Updated: September 1, 2025

Effective Date: January 1, 2024

Medical Connect, LLC, together with its subsidiaries and affiliates (collectively, “Company” “us,” “we,” or “our”) is committed to protecting the privacy of “Consumer Health Data” as defined by applicable law. This Consumer Health Privacy Notice describes how we and the Medical Groups process Consumer Health Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person interactions, events, and purchases; and other online and offline interactions.

Protected Health Information

Please see the Medical Groups’ Notice of Privacy Practices to understand how we protect, use and disclose your protected health information as defined under the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations (“HIPAA”). If your Personal Data is protected health information, we treat the protected health information in accordance with HIPAA and the Notice of Privacy Practices. However, any Personal Data that does not constitute protected health information under applicable laws, may be used or disclosed in any manner permitted under this Privacy Policy.  To the extent this Privacy Policy conflicts with our HIPAA obligations or the Notice of Privacy Practices, we comply with HIPAA obligations or the Notice of Privacy Practices.

Scope: This Consumer Health Privacy Notice does not apply to the data about our own employees, contractors, agents, and job applicants or to data that is protected under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations. 

Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Consumer Health Data with us.

Changes: We may update this Consumer Health Privacy Notice from time to time. Any updated Consumer Health Privacy Notice will be effective when posted. Please check this Consumer Health Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Consumer Health Privacy Notice.

1. Sources of Consumer Health Data

We collect Consumer Health Data about you from the following sources:

1. Directly from you. We may collect Consumer Health Data you provide to us directly, such as when you contact us through our Digital Properties, interact with us in person, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
2. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
3. From third parties. We may collect Consumer Health Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
4. From publicly available sources.  We may collect Consumer Health Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Consumer Health Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

2. Types of Consumer Health Data We Collect 

We may collect the following types of Consumer Health Data:

1. Health status or treatment information, such as health conditions or diagnoses; health treatments and services (such as surgeries, procedures, or other mental or physical interventions); medications; and bodily functions, including vital signs, symptoms, or health measurements.
2. Inferences about health derived from other health or non-health data, such as  precise location information that may indicate an attempt to acquire health services or supplies.

3. How We Use Consumer Health Data

We may use Consumer Health Data for the following purposes:

1. To provide you products and services, such as making our Digital Properties, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
2. For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
3. For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
4. For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
5. In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
6. For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Consumer Health Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the information in Section 7 (Contact Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Consumer Health Data

We disclose the Consumer Health Data described above to third parties, including the categories of recipients described below:

1. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership. 
2. Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
3. Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
4. Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
5. Law enforcement, government agencies, and other recipients, when required by law.
6. Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
7. Business partners that may use Consumer Health Data for their own purposes, such as:

• Advertisers, ad platforms and networks, and social media platforms;
• Third parties whose cookies and tracking tools we use as described in our Section 5 (Cookies and Other Tracking Technologies) below.
• Commercial data partners to whom we make information available for their own marketing purposes; and
• Partners who work with us on promotional opportunities, including co-branded products and services.

8. The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Consumer Health Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public. 
9. Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

Our Digital Properties and authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties, which may include Consumer Health Data. This section contains additional information about: 

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

1. Types of cookies and tracking technologies we use

We and the third parties that we authorize may use the following tracking technologies:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
• Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages. 
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties

2. Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

• Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties; 
• Improving performance, such as maintaining and improving the performance of our Digital Properties; 
• Analytics, such as analyzing how our websites are used. For example, we use Google Analytics to help us improve the user experience.  Google Analytics may use cookies and other tracking technologies to perform their services.  To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners; 
• Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and
• Security, such as preventing fraud and malicious behavior

3. Information collected

These tracking technologies collect data about you and your device, such as your IP address, location (both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

4. Disclosures of your information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.  

5. Your choices

Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a Company advertisement and follow the instructions on how to opt out. 

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. 

6.  Data Subject Rights

Nevada and Washington

Nevada and Washington consumers may have certain rights regarding your Consumer Health Data:

• Right to Access. You may have the right to confirm whether we process your Consumer Health Data and to obtain information about how we process such data. 
• Right to Delete. You may have the right to request that we delete Consumer Health Data concerning you.
• Right to Withdraw Consent. If you provided consent to process Consumer Health Data,  you may have the right to withdraw such consent.
• Right to Know. You may have the right to request a list of third parties with whom we’ve sold or shared your Consumer Health Data

You may exercise the rights available to you by emailing us at support@mytrustmedical.com.

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California

In addition to the rights above, the California Consumer Privacy Act provides California consumers with certain rights, such as the right to obtain from us information about the personal information about you that we collect, use, and disclose as set forth below.

Disclosure of Personal Information We Collect About You

You have the right to know:

• The categories of personal information we have collected about you;

• The categories of sources from which the personal information is collected;

• Our business or commercial purpose for collecting or selling personal information;

• The categories of third parties with whom we share personal information, if any; and

• The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

• Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or

• Provide the personal information to you more than twice in a 12-month period.

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Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

• The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, contact us as provided below.

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Right to Deletion 

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: 

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records. 

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Please note that we may not delete your personal information if it is necessary to: 

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; 

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; 

• Comply with the California Electronic Communications Privacy Act; 

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; 

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; 

• Comply with an existing legal obligation; or 

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

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Protection Against Discrimination 

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: 

• Deny goods or services to you; 

• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; 

• Provide a different level or quality of goods or services to you; or 

• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. 

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

If you would like to exercise any of these rights, please: 

• Email us at support@mytrustmedical.com. 

• Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period. 

• If you choose to contact directly by email, you will need to provide us with: 

o Enough information to identify you (e.g., your full name, address and customer or matter reference number); 

o Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and 

o A description of what right you want to exercise and the information to which your request relates. 

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. 

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of your verification.

7. Contact Information

If you have questions regarding this Consumer Health Privacy Notice, please contact us at:

support@mytrustmedical.com.