Consumer Health Data Privacy Policy

1. Introduction

This Consumer Health Data Privacy Policy supplements our Privacy Policy and applies specifically to "consumer health data" as defined by applicable state laws, including the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, and the Connecticut Data Privacy Act.

This policy applies to residents of states with consumer health data privacy laws and describes how Nuv, a brand of HealthFare Group, LLC ("Nuv") collects, uses, shares, and protects consumer health data.

2. What is Consumer Health Data?

Consumer health data includes personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. This includes data collected outside of a HIPAA-covered relationship. Examples include:

• Health conditions, diagnoses, or treatment information
• Biometric data used for identification
• Physical or mental health status information
• Reproductive or sexual health information
• Browsing or search history related to health topics on our Platform
• Location data that could indicate visits to health-related facilities
• Device identifiers and IP addresses when used in connection with health-related browsing
• Health data inferred or generated from other personal information

3. Categories of Consumer Health Data We Collect

3.1 Data You Provide Directly

• Health assessment responses (weight, height, medical history, health goals)
• Treatment preferences and medication interests
• Communications about your health with our team

3.2 Data Collected Automatically

• IP address and approximate location when browsing health-related pages
• Device identifiers linked to health-related browsing activity
• Pages visited on our Platform (e.g., GLP-1 weight loss page, peptide therapy information)
• Interaction with health-related features (BMI calculator, treatment selector)

3.3 Data Inferred or Generated

• Health interests inferred from browsing patterns
• Treatment eligibility determinations based on assessment responses
• BMI calculations and projected weight loss estimates

4. How We Use Consumer Health Data

• Providing and improving healthcare services through the Platform
• Connecting you with appropriate healthcare providers
• Processing prescriptions through Strive Pharmacy
• Personalizing your experience and treatment recommendations
• Analytics to improve our services and Platform performance
• Compliance with legal and regulatory obligations

5. How We Share Consumer Health Data

We may share consumer health data with:

• Healthcare Providers: Licensed physicians providing your care through the Platform
• Strive Pharmacy: For prescription fulfillment and medication delivery
• Service providers: Companies that help us operate the Platform (hosting, analytics) under contractual obligations to protect your data
• Legal requirements: When required by law, regulation, or legal process

We do not sell consumer health data. We do not share consumer health data for advertising purposes without your explicit consent.

6. Your Rights

If you are a resident of a state with consumer health data privacy laws, you have the following rights:

• Right to confirm: Confirm whether we have collected or shared your consumer health data
• Right to access: Obtain a copy of your consumer health data
• Right to correct: Request correction of inaccurate consumer health data
• Right to delete: Request deletion of your consumer health data (subject to legal retention requirements and HIPAA obligations)
• Right to withdraw consent: Withdraw consent for future collection or sharing of your consumer health data
• Right to appeal: Appeal a denied rights request

To exercise any of these rights, contact us at clinic@healthfaregroup.com or call +1 (561) 631-5134. We will respond within the timeframe required by applicable law.

7. Geofencing

Nuv does not use geofencing technology around healthcare facilities, pharmacies, or other health-related locations for the purpose of collecting consumer health data or identifying individuals seeking healthcare services.

8. Data Security

We implement reasonable security measures to protect consumer health data, including encryption, access controls, and regular security assessments. For more details, see the Security section of our Privacy Policy.

9. Data Retention

We retain consumer health data only as long as necessary for the purposes described in this policy, subject to legal retention requirements. Medical records are retained for a minimum of 7 years as required by Florida law. Non-medical consumer health data (e.g., browsing data) is retained for up to 26 months.

10. Changes to This Policy

We may update this policy to reflect changes in applicable laws or our practices. Changes will be posted on this page with an updated "Last updated" date.

11. Contact

For questions about this Consumer Health Data Privacy Policy, contact us at:

• Email: clinic@healthfaregroup.com
• Phone: +1 (561) 631-5134
• Address: 1500 W Cypress Creek Road, Fort Lauderdale, FL 33309