Tempo Meds Privacy Policy

Summary

• We collect the information needed to connect you with licensed healthcare providers, fulfill your orders, and run our business.
• Health information you give your provider for your care is protected under HIPAA, is held by the Medical Group, and is handled under the Medical Group’s Notice of Privacy Practices. We do not access or store it.
• We do not sell your health information. Advertising cookies are off unless you turn them on, and you can turn them off at any time through the “Your Privacy Choices” link.
• We do not use advertising or social media tracking tools to collect information about your health conditions, medications, or treatment.
• Depending on where you live, you may have rights to access, correct, and delete your information and to opt out of certain uses. See Section 10.

1. How Your Health Information Is Protected

• Information you provide for your care. Healthcare services offered through our platform are provided by [MEDICAL GROUP LEGAL NAME(S)] and its affiliated licensed providers (the “Medical Group”). The Medical Group is a “covered entity” under the Health Insurance Portability and Accountability Act (HIPAA). Information you provide to receive care, such as your questionnaire responses, medical history, prescriptions, and messages with your provider, is protected health information (“PHI”) of the Medical Group. The Medical Group’s Notice of Privacy Practices describes how it uses and discloses your PHI and your rights under HIPAA.
• Our role. Tempo Meds is not a healthcare provider, and we do not receive, access, or store your PHI. Your PHI is kept by the Medical Group and by the technology provider that operates the questionnaire, patient account, and provider messaging tools for the Medical Group under a business associate agreement. If this Privacy Policy and the Medical Group’s Notice of Privacy Practices conflict about PHI, the Notice of Privacy Practices controls.
• Other information. This Privacy Policy covers the other information we collect and use for our own purposes, such as account, order, subscription, payment and shipping status, website usage, and marketing information. Some of this information may relate to your health (for example, the fact that you ordered a weight loss medication). We treat that information as sensitive and handle it as described in this Policy and our Consumer Health Data Privacy Policy.

2. Information We Collect

Information you give us

• Contact and account information: name, email address, phone number, shipping and billing address, username, and password.
• Demographic information: date of birth and sex.
• Order and subscription information: the products you order, your plan, renewal dates, and order, payment, and shipment status.
• Payment information: your payment card or other payment details, which are collected and processed by our payment processor. We receive limited information such as the card type, last four digits, and billing address.
• Communications: messages you send us, customer support conversations, survey responses, and reviews.

Health information you give the Medical Group to receive care (for example, medical history, symptoms, medications, allergies, height and weight, photos you submit to your provider, and identity verification images) is collected through the Medical Group’s questionnaire and patient account and is governed by its Notice of Privacy Practices, as described in Section 1.

Information collected automatically

• When you use the Services, we and our service providers automatically collect information such as your IP address, device and browser type, operating system, pages viewed, links clicked, referring website, the date and time of your visit, and approximate location derived from your IP address. We use cookies, pixels, software development kits, and similar technologies to do this. See Section 4.

Information from others

• The Medical Group, Pharmacies, and our platform provider: for example, whether a prescription was issued, order and shipping status, and information needed to manage your account and orders. We do not receive your clinical records.
• Service providers: such as payment processors and shipping carriers.
• Marketing and advertising partners: such as information about how you arrived at our site or responded to an ad.

3. How We Use Information

We use the information we collect to:

• create and manage your account and verify your identity and eligibility;
• connect you with the Medical Group and support the healthcare services it provides;
• process payments, fulfill and ship orders, and manage subscriptions, including sending renewal reminders;
• communicate with you about your account, orders, and questions, and provide customer support;
• send you marketing communications, where permitted by law and subject to your choices;
• understand how the Services are used, fix problems, and improve our products and services;
• protect the security and integrity of the Services and prevent fraud; and
• comply with legal obligations, respond to lawful requests, and enforce our Terms.

We do not use PHI for marketing. The Medical Group may not use or disclose your PHI for marketing without your written authorization as required by HIPAA.

4. Cookies, Pixels, and Similar Technologies

• Essential technologies make the Services work, for example keeping you signed in and processing your order.
• Analytics technologies help us understand how visitors use the Services so we can improve them.
• Advertising technologies help us measure the effectiveness of our ads and show you our ads on other websites. They are off by default and run only if you turn them on in Cookie Settings.
• Our commitment on health information. We do not allow advertising, social media, or other third-party tracking technologies to receive information that identifies your health conditions, symptoms, medications, or treatment. We do not use these technologies on pages where you complete a health questionnaire, check out, access your patient account, or communicate with a provider.
• Your choices. You can manage non-essential cookies through Cookie Settings and through your browser settings. We honor Global Privacy Control (GPC) signals as a request to opt out of the sale or sharing of personal information for the browser or device sending the signal. We do not currently respond to other “Do Not Track” signals.

5. How We Share Information

We share information as described below and otherwise with your consent.

• The Medical Group and Pharmacies, to provide care and fulfill prescriptions.
• Service providers that perform services for us under contracts that limit their use of the information, including hosting and platform providers, payment processors, shipping carriers, customer support and communications providers, and analytics providers. Our website, questionnaire, checkout, patient account, and messaging tools are operated with the help of third-party technology providers.
• Advertising partners, only if you turn on advertising cookies, limited to information that does not reveal your health conditions or treatment, and subject to your opt-out choices described in Section 10.
• For legal reasons, when we believe in good faith that disclosure is required by law, subpoena, or other legal process, or is necessary to protect the rights, property, or safety of you, us, or others.
• In a business transfer, such as a merger, acquisition, or sale of assets, subject to applicable law. We will notify you before your personal information becomes subject to a different privacy policy.
• With your direction or consent.
• Text messaging. Mobile information will not be shared with third parties or affiliates for their marketing or promotional purposes. Text messaging opt-in data and consent will not be shared with any third parties, except service providers that help us deliver messages.

6. De-identified and Aggregated Information

• We and our platform provider may create information that is de-identified or aggregated so that it can no longer reasonably be linked to you, and use it to understand trends and improve the Services. We maintain this information in de-identified form, do not attempt to re-identify it, and require anyone we share it with to agree not to re-identify it. PHI is de-identified only in accordance with HIPAA’s de-identification standards.

7. How Long We Keep Information

We keep personal information for as long as needed for the purposes described in this Policy, including providing the Services, meeting legal, tax, and accounting requirements, resolving disputes, and preventing fraud. Our general retention periods are:

• Account and order records: [7 years after your last order, for tax, accounting and legal requirements]
• Marketing preferences and consent records: [until you opt out, plus 4 years to prove consent]
• Customer support conversations: [3 years after the conversation]
• Website analytics and cookie data: [up to 13 months]

Medical records are kept by the Medical Group as required by state medical record laws.

8. How We Protect Information

• We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest for sensitive data, access controls, and monitoring. No system is completely secure, and we cannot guarantee the security of information. If a security incident affects your information, we will notify you as required by law.

9. Your Choices

• Marketing emails: use the unsubscribe link in any marketing email.
• Text messages: reply STOP to any message, or contact us.
• Cookies and advertising: use Cookie Settings, your browser settings, or a GPC signal.
• Your account: review and update your account information by signing in, or contact us at info@tempomeds.com.

10. Your State Privacy Rights

Residents of California and a growing number of other states, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, have rights over their personal information. Subject to exceptions in the law, these may include the right to:

• know and access the personal information we have about you and obtain a copy in a portable format;
• correct inaccurate personal information;
• delete personal information;
• opt out of the sale of personal information, targeted advertising (called “sharing” in California), and certain profiling;
• limit or consent to our use of sensitive personal information, including health information;
• appeal our decision on your request; and
• not be discriminated against for exercising your rights.

PHI that is governed by HIPAA is generally exempt from these laws and is handled through the Medical Group’s Notice of Privacy Practices.

How to make a request

• Submit a request at [PRIVACY REQUEST WEB FORM URL], email info@tempomeds.com, or call (929) 201-8412. To opt out of sale or sharing, use the “Your Privacy Choices” link at the bottom of any page or enable GPC.
• We will verify your identity by matching information you provide to information we already have. You may use an authorized agent; we may ask for proof of the agent’s authority and to verify your identity directly.
• We will respond within 45 days, or tell you if we need up to 45 more days.
• If we deny your request, you may appeal by replying to our response or emailing info@tempomeds.com with the subject line “Privacy Appeal.” We will respond to appeals within 45 days. If you are not satisfied, you may contact your state attorney general.

11. Additional Information for California Residents

In the past 12 months, we have collected the following categories of personal information, from the sources and for the purposes described in Sections 2 and 3, and disclosed them as follows.

• We use sensitive personal information only to provide the Services you request and for other purposes permitted by California law, so we do not offer a separate right to limit its use.
• We do not knowingly sell or share the personal information of consumers under 16.
• Shine the Light. We do not disclose personal information to third parties for their own direct marketing purposes.

12. Children

• The Services are intended only for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact info@tempomeds.com and we will delete it.

13. Users Outside the United States

• The Services are intended for use only in the United States. Information we collect is stored and processed in the United States.

14. Links to Other Websites

• The Services may link to websites we do not operate. We are not responsible for their privacy practices, and we encourage you to review their privacy policies.

15. Changes to This Privacy Policy

• We may update this Privacy Policy from time to time and will post the updated version with a new “Last updated” date. If we make material changes, we will notify you by email or through the Services before they take effect. We will not use personal information we already have in a materially different way than described when we collected it without your consent.

16. Contact Us

For questions about your PHI or your HIPAA rights, contact the Medical Group’s Privacy Officer at [MEDICAL GROUP PRIVACY OFFICER EMAIL OR PHONE]. If you believe your HIPAA privacy rights have been violated, you may file a complaint with the Medical Group or with the U.S. Department of Health and Human Services, Office for Civil Rights, at www.hhs.gov/ocr/complaints. You will not be retaliated against for filing a complaint.

Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy applies to “consumer health data,” as defined by the Washington My Health My Data Act, Nevada law, and similar state laws, that BRS Ventures, Inc., a Delaware corporation doing business as Tempo Meds (“Tempo Meds,” “we,” or “us”) collects. It supplements our Privacy Policy. It does not apply to protected health information governed by HIPAA, which is held by the Medical Group and handled under its Notice of Privacy Practices.

Notice of Privacy Practices

The Medical Group’s Notice of Privacy Practices describes how it uses and discloses your protected health information and explains your rights under HIPAA. This is a separate document provided by the Medical Group.

Notice of Privacy Practices

[NOTICE OF PRIVACY PRACTICES URL]

For questions about this notice or your HIPAA rights, contact the Medical Group’s Privacy Officer at [MEDICAL GROUP PRIVACY OFFICER EMAIL OR PHONE].