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Privacy Policy

Effective Date: Sep 9, 2025

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Introduction

This Privacy Policy ("Privacy Policy") describes the data protection practices of Buttoned Up Leads LLC doing business as Palm Beach Labs ("Palm Beach Labs," "we," "our," or "us"). We refer to the Websites, Apps, and other services provided by Palm Beach Labs together in this Privacy Policy as the "Services." This Privacy Policy is incorporated into our Terms of Service. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Service.
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If you are a Washington state resident, please click here to view our Washington My Health My Data Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

This Privacy Policy contains the following sections:

• The Information We Collect and the Sources of Such Information
• Purposes for How We Use Your Information
• Online Analytics and Advertising
• How We Share and Disclose Your Information
• Your Marketing Choices
• Health Information and Third Party Services
• How We Protect Your Information
• Privacy Information for California Residents
• Privacy Information for Nevada Residents
• Retention of Your Information
• Revisions to Our Privacy Policy
• Contacting Us

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The Information We Collect And The Sources Of Such Information

We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.
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1. Information You Provide to Us

We collect a variety of information that you provide directly to us. For example, we collect information from you through:

• Account and product registration and administration of your account
• Processing your orders and requests for treatment
• Questions, communications, or feedback you submit to us via forms or email
• Your participation in research, surveys, contests, and sweepstakes
• Requests for customer support and technical assistance, including through online chat functionalities
• Uploads or posts to the Services
• Employment applications you submit

The specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:

• Name, address, telephone number, date of birth, and email address
• Information about your medical conditions, treatment options, physician referrals, lifestyle and personal preferences, prescriptions, medical photos, and lab results or other related health information, such as your physical and emotional characteristics
• Log-in credentials, if you create an account
• Billing and financial information, such as shipping address, credit or debit card number, verification number, and expiration date, collected by our payment processors on our behalf
• Identity verification information (e.g. driver's license or other government-issued ID card or number), and your signature (if required for notarization purposes)
• Information about purchases or other transactions with us
• Information about your customer service and maintenance interactions with us
• Demographic information such as your gender, race/ethnicity, and age, marital status and number of children, and similar information that may be required in connection with the Services
• Information about others, such as if you share a family or friend's email address or contact information to allow access to your information or name them as an emergency contact
• User-generated content you post in public online forums on our Services or share with other users
• Your location
• Any other information you choose to directly provide to us in connection with your use of the Services.

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2. Information We Collect Through Automated Means

We collect certain information about your use of the Services and the devices you use to access the Services, as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies, SDKs, pixels, and similar tools, to assist in collecting this information.

Our Websites. When you use our Websites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, your time zone, error logs, and other similar information.

Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, mobile device's GPS signal, information about nearby WiFi access points and cell towers, city/state and or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user's general location (e.g., to provide you with accurate sales tax information and to deliver content customized to your location).

We will ask your permission before collecting your precise GPS location information. In such instances, we will use your precise geo-location information to provide customized services, content, promotional offers and other information that may be of interest to you. If you no longer wish for us and our service providers to collect and use GPS location information, you may disable the location features on your device. Please see your device manufacturer settings.

Our Use of Cookies and Similar Online Tools. To collect the information discussed in this Section, and with your consent, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies to offer you a more tailored experience.

• A web server log is a file where website activity is stored.
• An SDK is a set of tools and/or code that we embed in our Apps and software to allow third parties to collect information about how users interact with the Services.
• A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer/device; (ii) store your preferences and settings; (iii) understand the parts of the Services you have visited and used; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.  

When you first access the Palm Beach Labs Services, you will be prompted to accept, deny or modify your cookie choices through our Cookie Consent. You may update your preferences at any time by clicking "Your Privacy Choices" at the bottom of the site.  Please also refer to our Cookie Notice for more information on cookies.

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3. Information We Collect From Social Media and Other Content Platforms

When you "like" or "follow" us on Facebook, Instagram, Twitter, or other social media platforms, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media platforms.

If you access the Services through a third-party connection or log-in (e.g., through a social network or third-party authentication tool), you may allow us to have access to and store certain information from such third parties depending on your settings on such services. If you do not wish to have this information shared, do not use these connections to access the Services. For a description of how these third parties handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.

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4. Information We Receive From Other Sources

We work closely with third parties (including, for example, third party service providers, such as physicians, medical professionals, and pharmacies to provide you with the Services, as well as with advertising networks, analytics providers, marketing partners, and search information providers). Such third parties will sometimes provide us with additional information about you.

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How We Use Your Information

In connection with providing you with the Services, unless you opt out through our Cookie Consent, we may use your information for our business purposes to:

• Carry out, improve, and manage the Services and, as applicable, facilitate the provision of health care services to you by physicians or other health care providers and ensure that the physicians or health care providers have the services and support necessary for health care operations.
• Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.
• Communicate with you about the Services, your use of the Services, or your inquiries related to the Services and send you communications on behalf of physicians, pharmacies, or other health care providers utilizing the Services to meet your needs.
• Communicate with you (in accordance with applicable legal requirements) by email, postal mail, or phone about surveys, promotions, special events or our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.
• Provide you with technical support and customer service, and troubleshoot any technical issues or errors.
• Verify your identity and administer your account, including processing your payments, fulfilling your orders, and verifying the authenticity of your government-issued identification photo.
• Ensure that content from our Services is presented in the most effective manner for you and for your computer or device, allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Services safe and secure.
• Provide you with more relevant advertisements and personalized content, and measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.
• Help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Services.
• Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others, including to prevent potentially prohibited or illegal activities..
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others, such as protecting against malicious, fraudulent, or illegal activity.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
• Any health information we collect about you may also be subject to additional protections under your state’s laws. We will only use, process and disclose that information, and will instruct any third-party who process that information on our behalf to use health data, in accordance with applicable laws and regulations in your state of residence.

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Combined Information.

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy and your consent where required by applicable law.

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Aggregate/De-Identified Data.

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device ("Aggregate/De-Identified Information"). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

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Online Analytics And Advertising

1. Online Analytics

We may use third-party web analytics services (such as those of Google Analytics (including Google Signals, Google User-ID, and other Google Analytics features) and MixPanel) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. If you have a Google account with personalized advertising enabled, through Google Signals, Google will also be able to gather for us analytics and engagement information from across the various devices you use to access the Services. To prevent Google from using your information for analytics (including cross-device tracking for personalization purposes), you may install the Google Analytics Opt-out Browser Add-on by clicking here. And to opt out of Google Signals, please open your "Settings" app, locate and tap "Google," select "Ads," and turn ON "Opt out of Ads Personalization." You may also be able to disable cross-device tracking through your Android or Apple device-based settings.

If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

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2. Online Advertising

The Services may integrate third-party advertising technologies (e.g., ad networks and ad servers such as Facebook, Google Ad Words, TikTok, Criteo and others) that use cookies, pixels, and other technologies to deliver relevant content and advertising for Palm Beach Labs products on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services. If you do not wish to receive targeted advertising, please update your settings via the Cookie Consent.

We sometimes provide our customer information (such as email addresses) to service providers, who may "match" this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications. We may also share customer information such as your email address with third-party advertising networks that use such information to better target advertising to you regarding Palm Beach Labs products and services, as well as other products and services, as you browse the internet.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by non-affiliated third party advertising network services. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. To update your advertising preferences with Facebook, click here. To update your advertising preferences with TikTok, click here. We do not control these opt-out links, whether these opt-out links change over time, or whether any particular company chooses to participate in the industry opt-out programs listed above. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above or through the Cookie Consent, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

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3. Mobile Advertising

When using third party mobile applications, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.

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How We Share And Disclose Your Information

NOTICE: We may sell your sensitive personal data.

With your consent where required, we may share your information for our business purposes in the following ways:

• Affiliates and Subsidiaries. We may share information we collect within Palm Beach Labs to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.
• Health Care Providers and Services. We share your information with third-party health care providers: (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.
• Service Providers. We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services to us, including billing, credit card processing, content/service enhancements, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing, consulting, and legal services. These entities may also include health care organizations, pharmacies, and other third parties we use to support our business or in connection with the administration and support of the Services.
• Advertising Networks (unless you opt out). Please see the "Online Advertising" section above for details about how we share information with advertising partners.
• Joint Service Providers. These are entities that jointly offer or provide services or products with us through the Palm Beach Labs platform. These entities collect and use data in accordance with their own terms and privacy policies.
• Protection of Palm Beach Labs and Others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Palm Beach Labs, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
• Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
• Public Forums/User Interactions. Certain features of our Services make it possible for you to share comments publicly or with other users. Any information that you post publicly is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review on one of our Websites, we may display your review (along with the name provided, if any) on other Palm Beach Labs Websites and on third-party websites. Any information you post openly in these ways will be available to the users you shared it with and potentially the public at large, and may be accessible through third-party search engines. Accordingly, please take care when using these features. We are not responsible for how others use the information about you that you share with them through the Services.
• Testimonials/Reviews. We may, directly or indirectly, via phone, email, third-party application and other methods, solicit or invite you to submit product or service reviews, written, video, or otherwise. If you choose to submit information in response to this solicitation, including name, likeness, image, product or service review, or any other materials, you consent to our use of your name, likeness, and other information in marketing materials, or testimonials on our website or third-party websites.
• Consent. We may also disclose your information in other ways you direct us to and when we have your consent.
• Aggregate/De-Identified Information. We reserve the right to create Aggregate/De-Identified Data from the information we collect through the Services and our sharing of such Aggregate/De-Identified Data is in our discretion.

We do not share your data internationally at this time. 

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Your Choices

You may request that we update or delete your personal information by sending us an email at legal@palmbeachlabs.co. We will use commercially reasonable efforts to correct or delete your information. Please see “Your Rights” below for more about your data rights.

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Opt-out of Communications:

You may opt out of communications or marketing-related emails by clicking the “Unsubscribe” link at the bottom of each such email. You may continue to receive Service-related and other non-marketing communications by following the instructions in a particular communication (such as a text message) or by sending an email with your communication preferences to legal@palmbeachlabs.co.

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Disabling Cookies:

In addition to updating your preferences in our Cookie Consent, you may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the "help" section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe's Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

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Your Rights

Your local laws may permit you to request that we:

• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update or rectify information which is out of date or incorrect;
• delete certain information which we are holding about you;
• oppose, cancel, or restrict the way that we process and disclose certain information;
• transfer your information to a third-party provider of services;
• revoke your consent for the processing of your information.

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We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests, to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. If you would like further information in relation to your legal rights under applicable law, or would like to exercise those rights, please email legal@palmbeachlabs.co. Please be sure to include your name, address (including the state where you reside), and email address so we can respond to your request in the time frame required under your state’s laws.  

If you submit a request and we deny your request, you also may have the right to appeal such determination.  To appeal, please submit your request with the subject line “Data Rights APPEAL” to legal@palmbeachlabs.co, along with the original determination and reason for appeal.  We will comply with the laws of your state of residence when processing and resolving such appeal request.  You may also file a complaint with your state’s attorney general if you think your appeal or request was not handled in accordance with your state’s laws. You can find contact information for your state’s attorney general at “Find My AG”.

Shine the Light Disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.

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How We Protect Your Information

Palm Beach Labs takes a variety of technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk. Where we have given you (or where you have chosen) a password that enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the Services.

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Children

We do not knowingly allow individuals under the age of 18 to create accounts that allow access to our Services. If we learn that we have collected personal information directly from a child under the age of 13 through our Services, we will take reasonable steps to delete that information as soon as practicable. If you believe someone under the age of 13 has provided us with personal information, please email legal@palmbeachlabs.co.

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Retention Of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

To determine the appropriate retention period for your information, we will consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we use your information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

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Revisions To Our Privacy Policy

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites or Apps after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Privacy Policy.

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Contacting Us

If you have any questions or concerns about our Privacy Policy, or if you wish to submit a data subject access, deletion, or opt-out request according to the state law where you reside, please contact our privacy officer at legal@palmbeachlabs.co. Please be sure to include your name, address (including the state where you reside), and email address so we can respond to your request in the time frame required under your state’s laws.

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COOKIE NOTICE

We use cookies to collect information about your browsing activities over time and across different web Services following your use of our Services. They allow us to recognize and count the number of users, to see how users move around the Services when they are using it and assess our internal performance and functionality needs. This helps us to improve the services we provide to you and the way the Services works. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.  

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In addition to cookies that are “strictly necessary” which are required for the proper operation of our Services, we may use the following cookies:

Functionality cookies: these cookies record information about choices you’ve made and allow us to tailor our Services to you. These cookies mean that when you continue to use or come back to our Services, we can provide you with our Services as you have asked for them to be provided.

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These cookies allow us to:

• Save your location preference if you have set your location on your homepage;
• Remember settings you have applied, such as layout, text size, preferences, and colors;
• Show you when you are logged in; and
• Show you when you are logged in; and
• Store accessibility options.

Performance and Analytics cookies: these cookies help us analyze how our Services are accessed, used, or are performing in order to provide you with a better user experience and to maintain, operate and continually improve our Services. They allow us to count visitors and traffic to our Services. All information collected from analytic cookies is aggregated so it is not identifiable.

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These cookies allow us to:

• Better understand our Services visitors so that we can improve how we present our content;
• Test different design ideas for pages, such as our homepage;
• Collect information about visitors of our Services such as where they are located and what browsers they are using;
• Determine the number of unique users of our Services;
• Improve our Services by measuring any errors that occur; and
• Conduct research and diagnostics to improve product offerings.

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Marketing: We may use Google pixels and Microsoft Bing and Meta marketing cookies to help in our marketing efforts.

Alternatively, you can change your preferences by changing the settings in your browser. Most browsers will allow you to choose the level of privacy settings you want. This lets you control your cookie settings so that you can:

• See what cookies or other locally stored data you’ve got and delete them on an individual basis;
• Block third party cookies or similar technology;
• Block cookies or similar technology from websites;
• Block all cookies or similar technologies from being set; or
• Delete all cookies or similar technologies when you close your browser.

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For more information on how to manage the most popular browsers, please see below:

Microsoft

Edge

‍Firefox

‍Google Chrome

‍Safari

HIPAA Notice of Privacy Practices

When it comes to your protected health information (PHI), Palm Beach Labs follows the requirements of the Health Insurance Portability and Accountability Act (“HIPAA”). This section describes how we may use and disclose your health information, and what rights you have regarding it.

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Your Rights

You have the right to:

• Access your medical record – You can request an electronic or paper copy of your medical records and other health information we maintain. We will provide it within 30 days of your request, subject to a reasonable, cost-based fee.
• Request corrections – If you believe information we have is incomplete or incorrect, you can request that we correct it. If we deny the request, we will explain why in writing within 60 days.
• Confidential communications – You may request that we contact you in a specific way (e.g., only at your work phone or by mail to a different address). We will accommodate reasonable requests.
• Restrict disclosures – You may ask us not to use or share certain health information for treatment, payment, or operations. While we are not required to agree, we will comply unless sharing is legally required or necessary for your care. If you pay out-of-pocket in full, you can request that we not share that service with your insurer.
• Accounting of disclosures – You can request a list of disclosures we have made of your PHI (excluding certain routine disclosures) for up to six years prior. The first list in a 12-month period is free.
• Paper copy of this notice – You may request a paper copy of this Policy at any time.
• Authorize someone to act for you – A person with legal authority (medical power of attorney or guardian) may exercise your rights on your behalf.

File a complaint – If you believe your privacy rights have been violated, you may contact our Privacy Officer (see contact information below) or file a complaint with the U.S. Department of Health & Human Services at www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

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Your Choices

In certain situations, you have both the right and choice to direct us to:

• Share information with family, friends, or others involved in your care.
• Share information in a disaster relief situation.
• Include your information in a facility directory.

We will not share your PHI without written authorization for:

• Marketing purposes.
• Sale of your information.
• Most uses of psychotherapy notes.

We may contact you for fundraising efforts, but you can opt out at any time.

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Our Uses and Disclosures

We typically use and share PHI in the following ways:

• Treatment – Sharing information with providers who are treating you.
• Operations – Using PHI to run our practice, improve your care, and contact you when necessary.
• Payment – Sharing PHI to bill and obtain payment from health plans or other payors.

We may also share PHI when permitted or required by law, including for public health and safety, research, law enforcement, organ donation, medical examiners, workers’ compensation, national security, and legal proceedings.

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Our Responsibilities

• We are required by law to maintain the privacy and security of your PHI.
• We will notify you promptly if a breach occurs that may have compromised your information.
• We will not use or disclose your information other than as described in this Policy unless you authorize it in writing. You may revoke authorization at any time.
• We may update this Policy, and changes will apply to all information we maintain. Updated versions will be available on our website and upon request.
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Contact Information

If you have questions about this Privacy Policy or how your PHI is handled:

Privacy Officer

Email: privacy@palmbeachlabs.co

Phone: 888-368-0035

Mailing Address: 16192 Coastal Highway, Lewes, Delaware 19958

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You may also file a HIPAA complaint directly with the U.S. Department of Health and Human Services Office for Civil Rights:

• Website: www.hhs.gov/ocr/privacy/hipaa/complaints/
• Phone: 1-877-696-6775
• Mail: 200 Independence Avenue, S.W., Washington, D.C. 20201

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My Health My Data Privacy Policy

This notice is intended to supplement the Palm Beach Labs Health (“Palm Beach Labs”) Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (“MHMD”).

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Consumer Health Data We Collect

The data we collect depends on the context of your interactions with Palm Beach Labs and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data. As described in “Information We Collect” section of our Privacy Policy, the data we collect depends on the context of your interactions, but primarily comes from information you choose to submit to Palm Beach Labs information based on your privacy settings, and your location. Because consumer health data is defined very broadly, certain of the categories of data we collect could also be considered consumer health data.

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Examples of consumer health data may include:

• Information about your health-related conditions, injuries, symptoms, status, diagnoses, testing, medications, allergies, or treatments (including surgeries, procedures, medications, blood test results, or other interventions). For example, if you are looking to connect with a physician who is licensed in your state to provide you with a metabolic health assessment and prescribe medications, we may collect some or all of this information to provide the services.
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, if you allow Google Analytics in your cookie permissions, we may collect location data that could reveal your location and your interest in receiving health care services to connect you to a physician who is licensed in your state.
• Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, we may collect information about information you viewed, which may indicate your attempt to learn more about certain conditions that you or another person may have, or based on products descriptions you clicked on to explore whether certain prescription medications may be right for you.
• Other information that may be used to infer or derive data related to the above or other health information.

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Sources of Consumer Health Data

As described further in the Privacy Policy, we collect personal data (which may include consumer health data) directly from you and from your interactions with our Services. We may use cookies to collect certain information that you agree to in our Cookie Consent. We will not collect any information via cookies without your consent.

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Why we collect and use consumer health data

We collect and use consumer health data for the purposes described in the “How We Use Your Information”  section of the Privacy Policy. We collect personal data (which may include consumer health data) directly from you, from your interactions with our Services.

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law –for example, to respond to an inquiry through our Contact Us form. See the “Your Choices”  and “Your Rights”  sections of the Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

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How we share consumer health data

We may share each of the categories of consumer health data described above for the purposes described in the How We Share and Disclose Your Information section of the Privacy Policy. In particular, we may share personal data, including consumer health data, with your consent, when you tell us to do so, or as reasonably necessary to deliver the Services or respond to an inquiry, including sharing with physicians and pharmacies who are licensed in your area who want to provide you with products or services at your request. We may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

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With whom we share consumer health data

We provide certain health care providers and business partners with your consumer health data so that we can provide you with the services you requested. For example, if you are connected to a physician who is licensed in your state to provide you with products or services, we need to provide your consumer health data to that physician so they can perform a health assessment and, if applicable, prescribe certain medications. We may also share your consumer health data with pharmacy partners so they can fill your prescription. When you create an account with Palm Beach Labs, you authorize us to collect and provide this information to these partners. As necessary for the purposes described above and to provide you with the Service, we share consumer health data with the following categories of third parties:

• Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to protect and secure data, or provide products or services you are interested in, may need access to data to provide those functions.
• Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
• Government agencies. As described in our Privacy Policy we may be required to disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
• Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
• ‍Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.

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How to exercise your rights

Palm Beach Labs requires you to provide affirmative consent to (i) collection and (ii) sharing and (iii) sale of your consumer health data as described in this Policy and the Privacy Policy when you first access the services.

MHMD provides consumers with certain rights regarding their consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using emailing legal@palmbeachlabs.co to request access, correction, or deletion of consumer health information, or to withdraw consent from future collection or sharing of consumer health data. You may also opt out of Google Analytics services using the Opt-Out feature provided by Google or by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout.

If you submit a rights request to legal@palmbeachlabs.co, we will respond to that request within the period of time required under MHMD.

If your request to exercise a right under the MHMD is denied, you may appeal that decision by emailing legal@palmbeachlabs.co. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.