TELEHEALTH PRIVACY POLICY

1. Scope of This Privacy Policy

• This Privacy Policy applies to personal information processed by the Company through the Services unless another privacy notice expressly applies.
• This Privacy Policy does not replace a healthcare provider's Notice of Privacy Practices or other legally required notice governing protected health information.
• If a separate medical group, pharmacy, laboratory, payment processor, or other third party independently determines how it processes information, that party's privacy practices may also apply

2. Information We Collect

• Identifiers and contact information: name, email address, telephone number, date of birth, mailing address, shipping address, account identifiers, and similar information.
• Account and transaction information: account credentials, order history, subscription status, transaction details, billing information, and limited payment-related information. Full payment-card details may be processed directly by third-party payment processors rather than stored by us.
• Health and wellness information: medical history, current medications, allergies, symptoms, treatment goals, lifestyle information, measurements, questionnaire responses, prescription history, uploaded documents, and other information submitted in connection with an assessment or healthcare service.
• Communications: customer-support requests, emails, chat messages, telephone communications, survey responses, and other correspondence.
• Device and internet information: IP address, device identifiers, browser type, operating system, language, referring pages, approximate location derived from IP, and similar technical information.
• Usage information: pages viewed, clicks, session activity, timestamps, navigation patterns, conversion events, and interactions with the Services.
• Cookies and similar technologies: cookies, pixels, SDKs, local storage, tags, and related technologies used for functionality, analytics, security, preferences, and - where permitted - advertising or measurement.
• Information from third parties: information received from healthcare providers, pharmacies, laboratories, identity-verification services, payment processors, marketing partners, analytics providers, service vendors, or other sources as permitted by law.

3. Sensitive and Consumer Health Information

• Certain information we process may be considered sensitive personal information, consumer health data, or protected health information depending on the context and applicable law.
• Health-related information may include diagnoses, symptoms, medications, treatment interests, reproductive or sexual-health information, weight-related information, laboratory information, and inferences that could reveal a person's physical or mental health status.
• We use and disclose sensitive or consumer health information only for purposes permitted by applicable law and, where required, with appropriate consent or authorization.
• INFORMED CONSENT

4. How We Use Information

• Provide, operate, maintain, personalize, and improve the Services.
• Create and manage accounts and patient intake experiences.
• Connect users with licensed healthcare professionals and facilitate telehealth workflows.
• Coordinate prescriptions, pharmacy fulfillment, laboratory services, shipping, and related administrative functions where applicable.
• Process payments, subscriptions, refunds, and transactions.
• Provide customer support and respond to requests.
• Authenticate users, detect fraud, prevent misuse, protect security, and enforce our agreements.
• Analyze performance, diagnose technical issues, understand usage, and improve user experience.
• Send transactional, service, safety, account, or administrative communications.
• Send marketing communications where permitted and where any required consent has been obtained.
• Comply with legal, regulatory, tax, audit, reporting, licensing, recordkeeping, and law-enforcement requirements.
• Establish, exercise, or defend legal claims and protect the rights, safety, and property of users, providers, partners, and the Company.

5. Healthcare Providers and Clinical Information

• Information submitted through a healthcare intake may be made available to licensed healthcare professionals for clinical evaluation and treatment decisions.
• Licensed healthcare professionals exercise independent medical judgment and may collect or create additional medical information as part of the clinician-patient relationship.
• Medical records maintained by a healthcare provider or medical group may be governed by separate privacy obligations and retention requirements.
• Clinical services are provided by DrTelx, an independent telehealth medical group. DrTelx and the dispensing pharmacies are HIPAA covered entities and maintain their own medical records, privacy practices, and retention obligations, separate from this Policy. DrTelx's Notice of Privacy Practices is available at https://drtelx.com/privacy-policy/. Questions about your medical records, or requests to access, amend, or restrict them, should be directed to DrTelx at support@drtelx.com

6. HIPAA and Protected Health Information

• HIPAA does not automatically apply to every piece of health-related information collected through a consumer website or technology platform.
• Where the Company acts as a HIPAA covered entity or business associate, protected health information will be handled in accordance with applicable HIPAA requirements and contractual obligations.
• Where information falls outside HIPAA, it may still be protected by other federal or state privacy,
  consumer-protection, or consumer-health-data laws.
• Do not publish broad statements that all platform data is 'HIPAA compliant' unless counsel has confirmed the applicable entities, data flows, contracts, security controls, and permitted uses.

7. How We Disclose Information

• Healthcare providers and medical groups: to facilitate clinical evaluation, treatment, care coordination, and required medical recordkeeping.
• Pharmacies and laboratories: to process prescriptions, dispensing, fulfillment, laboratory orders, results, shipping, and related services.
• Service providers: hosting, cloud infrastructure, security, identity verification, customer support, communications, analytics, shipping, payment processing, fraud prevention, and other operational functions.
• Professional advisers: lawyers, accountants, auditors, insurers, compliance advisers, and consultants where reasonably necessary.
• Corporate transactions: in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, subject to applicable law.
• Legal and safety disclosures: where required by law, subpoena, court order, regulatory request, or where reasonably necessary to protect rights, safety, security, or prevent fraud or harm.
• With your direction or consent: when you request or authorize a disclosure.

8. Sale, Sharing, Targeted Advertising, and Marketing Disclosures

• We sell and share personal information as those terms are defined under applicable state privacy laws, including for cross-context behavioral advertising and targeted advertising. We use advertising and analytics technologies that disclose identifiers and browsing activity to third-party advertising partners. We do not use information that identifies you as having sought or received specific medical treatment for targeted advertising, and we do not sell consumer health data.
• To opt out of the sale or sharing of personal information, or of targeted advertising, email privacy@voyocare.com with your request and the email address associated with your account. We will respond within the timeframes required by applicable law.

9. Cookies, Analytics, and Similar Technologies

• We may use cookies and similar technologies for essential functionality, authentication, fraud prevention, preferences, analytics, measurement, and marketing where legally permitted.
• Depending on jurisdiction, we may ask for consent before using non-essential technologies.
• Users may be able to manage cookies through browser settings, consent-management tools, or our privacy controls.
• We do not currently recognize browser-based opt-out signals such as Global Privacy Control. To opt out of the sale or sharing of personal information or of targeted advertising, email privacy@voyocare.com with your request and the email address associated with your account

10. Payment Processing

• Payments may be processed by third-party payment processors. Those processors may collect payment-card, bank, billing, fraud-prevention, and transaction information under their own privacy terms.
• The Company may receive transaction identifiers, payment status, limited card metadata, and related information needed to manage orders and accounts.

11. Data Security

• We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, or disclosure.
• Safeguards may include encryption in transit, access controls, authentication, vendor controls, logging, monitoring, employee training, incident-response procedures, and other measures appropriate to the sensitivity of the information.
• No transmission or storage system can be guaranteed to be completely secure. Users should protect account credentials and notify us promptly of suspected unauthorized access.

12. Data Retention

• We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including service delivery, account administration, legal compliance, fraud prevention, dispute resolution, and enforcement of agreements.
• Medical records and information maintained by licensed healthcare providers may be retained for periods required by medical-record laws and professional obligations.
• Retention periods may vary by information type, jurisdiction, legal requirement, contractual obligation, and operational need.
• When information is no longer required, we may delete, de-identify, aggregate, or anonymize it as permitted by law.

13. De-Identified and Aggregated Information

• We may create de-identified, anonymized, or aggregated information that is not reasonably capable of being linked to an identifiable individual.
• Where required by law, we will take reasonable measures to prevent re-identification and will not attempt to re-identify data maintained as de-identified except as legally permitted.

14. Privacy Rights

• Depending on where you live, you may have rights to request access, correction, deletion, portability, or information about our collection, use, and disclosure of personal information.
• You may also have rights to opt out of certain sales, sharing, targeted advertising, profiling, or processing of sensitive information; withdraw consent; limit certain uses; or appeal a denied privacy request.
• Some information may be exempt from certain requests, including medical records retained under healthcare laws or information required for legal compliance.
• To submit a request, contact at privacy@voyocare.com.

15. Verification of Privacy Requests

• We may take reasonable steps to verify identity and authority before processing a privacy request.
• Verification requirements may vary based on the request, sensitivity of the information, and applicable law.
• Authorized agents may submit requests where permitted, subject to documentation and verification requirements.

16. State-Specific Privacy Rights

• Residents of certain U.S. states may have additional rights under state comprehensive privacy or consumer health data laws.
• Privacy Notice
• Where applicable, provide information regarding categories collected, sources, purposes, disclosure categories, retention, opt-out rights, appeals, sensitive-data processing, consumer-health-data authorization, and regulator complaint rights.

17. California Notice

This section applies to California residents and supplements the rest of this Policy.

Categories of personal information we collect. In the past 12 months we have collected: identifiers (name, email, postal address, phone number, IP address, account identifiers); customer records (billing and shipping details, payment status); commercial information (orders, subscription history); internet activity (pages viewed, referring source, interactions with our site and ads); geolocation inferred from IP address; and inferences drawn from the above for marketing and service purposes.

Sensitive personal information. We may collect information relating to health or medical treatment that you submit in connection with obtaining care. We use this information only to provide the Services, route your information to your treating provider and dispensing pharmacy, and comply with law. We do not use or disclose sensitive personal information for purposes other than those permitted under Cal. Civ. Code § 1798.121, and we do not use it for targeted advertising.

Sources. We collect information directly from you, automatically from your device when you use our site, and from our service providers, including payment processors, the medical group, and dispensing pharmacies.

Purposes. To provide and administer the Services; process orders, payments, and subscriptions; coordinate care with the medical group and pharmacies; provide customer support; prevent fraud; conduct analytics and measurement; market our Services; and comply with legal obligations.

Disclosures for a business purpose. In the past 12 months we have disclosed identifiers, customer records, commercial information, and health-related information to: the medical group and its providers; dispensing pharmacies; payment processors; shipping and fulfillment providers; hosting, email, and customer-support vendors; and analytics providers.

Sale and sharing. We sell and share personal information as those terms are defined under the CCPA, including identifiers and internet activity disclosed to advertising partners for cross-context behavioral advertising. We do not sell or share sensitive personal information, and we do not knowingly sell or share the personal information of consumers under 16.

Retention. We retain personal information for as long as needed to provide the Services and to satisfy legal, tax, accounting, and recordkeeping obligations, after which it is deleted or de-identified. Medical records are retained by the medical group and dispensing pharmacies under their own retention obligations, not ours.

Your rights. California residents have the right to know, access, correct, and delete personal information; to opt out of sale, sharing, and targeted advertising; to limit the use of sensitive personal information; and to be free from discrimination for exercising these rights.

How to submit a request. Email privacy@voyocare.com with your request and the email address associated with your account. We will verify your identity before responding. You may use an authorized agent, who must provide written permission and proof of identity.

Financial incentives. We do not offer financial incentive programs in exchange for personal information.

Shine the Light. California residents may request information about disclosures of personal information to third parties for their direct marketing purposes by emailing privacy@voyocare.com.

18. Consumer Health Data

Washington, Nevada, and Connecticut law require a separate notice for consumer health data. Our Consumer Health Data Privacy Policy describes the categories of consumer health data we collect, the sources and purposes of collection, the categories of third parties and affiliates with whom it is shared, your rights to access, delete, and withdraw consent, and how to submit a complaint. It is available at voyocare.com/consumer-health-data-privacy.

19. Marketing Communications

• You may opt out of promotional emails by using the unsubscribe mechanism in those messages or by contacting us.
• Text-message marketing is subject to separate consent and opt-out requirements where applicable.
• Opting out of marketing does not prevent service-related, transactional, safety, or legally required communications.

20. Children's Privacy

• The Services are intended for adults unless a specific service expressly states otherwise.
• We do not knowingly collect personal information from children under 13 through general-audience Services, and healthcare eligibility may require users to be at least 18.
• If you believe a child has provided personal information in violation of this policy, contact us at privacy@voyocare.com.

21. International Users and Data Transfers

• The Services are intended for use only by individuals located in the United States. We do not offer the Services to, or knowingly collect information from, individuals located outside the United States.
• All information we collect is processed and stored in the United States. If you access the Services from outside the United States, you do so on your own initiative and are responsible for compliance with local law. By using the Services, you understand that your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your location.

22. Third-Party Websites and Services

• The Services may link to third-party websites, applications, pharmacies, laboratories, social networks, or other services.
• We are not responsible for the independent privacy practices of third parties. Review their privacy notices before providing information to them.

23. Business Transfers

• Personal information may be transferred or disclosed in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to applicable law and required notices.

24. Changes to This Privacy Policy

• We may update this Privacy Policy as our Services, data practices, vendors, or legal obligations change.
• The revised policy will identify an updated effective date. We will provide additional notice or obtain consent when required by applicable law.

25. Contact Us

• Brand / Platform: Voyocare
• Legal Entity: PYLOT LLC
• Website: voyocare.com
• Privacy Email: privacy@voyocare.com
• Support Email: info@voyocare.com
• Business Address: 30 N Gould St, STE R, 82801, Sheridan, Wyoming
• Medical Group / Clinical Provider: DrTelx, an independent telehealth medical group (drtelx.com). Clinical services are provided by DrTelx and its licensed providers, not by PYLOT LLC. Clinical inquiries, medical records requests, and complaints about care should be directed to DrTelx.