Lunera Health LLC (“Lunera Health LLC,” “we,” “us,” or “our”) respects your privacy and values your trust. This Privacy Policy explains how we collect, use, disclose, and protect information that identifies you or can reasonably be linked to you (“Personal Information”) in connection with our activities in the United States.

This Privacy Policy applies to information we collect through:

• our website and its interactive features, forms, and messaging tools (the “Website”);
• email messages and other electronic communications we send to you that link to this Privacy Policy (“Emails”);
• SMS/text messages and phone communications, where permitted by law (“Texts/Calls”); and
• offline interactions, such as when you contact our support team (“Offline Interactions”).

The Website, Emails, Texts/Calls, and Offline Interactions are collectively referred to as our “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

RELATIONSHIP BETWEEN LUNERA LLC HEALTH AND RX COLLECTIVE

Lunera Health LLC operates a patient-facing telehealth technology and administrative platform and utilizes technology and operational infrastructure provided by Rx Collective to support certain Platform functions.

Medical services are provided by licensed healthcare professionals affiliated with independent Provider Groups. The applicable Provider Group and its healthcare professionals are responsible for clinical services, medical decision-making, diagnosis, treatment, prescribing, and clinical medical records.

Lunera Health LLC does not practice medicine and does not interfere with clinical judgment.

IMPORTANT HIPAA NOTICE (READ THIS)

Some information you provide may relate to your health, symptoms, medications, or treatment (“Health Information”).

• When Health Information is created, received, maintained, or used by the licensed healthcare professionals or Provider Groups providing your clinical care, it may constitute Protected Health Information (“PHI”) subject to the Health Insurance Portability and Accountability Act (“HIPAA”) and the applicable Provider Group’s Notice of Privacy Practices.
• Lunera Health LLC is not the healthcare provider or HIPAA Covered Entity responsible for the clinical services provided by the Provider Groups.
• This Privacy Policy describes Lunera Health’s practices concerning information it collects or receives through its Services for non-clinical purposes, including facilitating consultation requests, billing, customer support, and order fulfillment.

If you have questions regarding the use of your information in connection with clinical care, please contact us and we will direct you to the appropriate Provider Group or privacy notice.

CONTENTS

1. What Information Do We Collect?
2. How Do We Collect Personal Information?
3. How Do We Use Cookies and Similar Technologies?
4. Do We Collect Information from Children Under 18?
5. What Do We Do With the Information We Collect?
6. When Do We Disclose Information to Third Parties?
7. Does This Privacy Policy Apply to Other Websites?
8. How Do We Secure the Information We Collect?
9. Your Choices Regarding Marketing and Communications
10. Can You Update or Correct Your Information?
11. Changes to This Privacy Policy
12. Contact Us

1) WHAT INFORMATION DO WE COLLECT?

“Personal Information” is information that identifies you or relates to an identifiable individual. We may collect the following categories:

A. Contact Information

• Name, email address, phone number, and mailing address.

B. Account Information

• Username and password, if account creation is enabled, and account settings and preferences.

C. Identity & Eligibility Information

• Date of birth, identification information, and location, including state, where needed to verify eligibility for Services or facilitate access to healthcare services.

D. Health Information You Provide

Depending on how you use our Services, we may collect information that you provide directly to us before a clinical consultation, including:

• the treatment or services you are seeking; and
• information you provide in connection with initiating a consultation request.

Clinical notes, diagnoses, treatment plans, prescriptions, and other clinical documentation created by healthcare professionals in connection with your medical care are maintained under the responsibility of the applicable Provider Group and are not governed by Lunera Health’s practices under this Privacy Policy.

E. Commercial & Transaction Information

• Purchase history, billing information, order and fulfillment information, consultation occurrence or type, subscription status (if applicable), and transaction records.

Payments are typically processed through third-party payment processors. We do not store full payment card numbers.

F. Customer Support & Communications

• Communications with us, including emails, texts, form submissions, and customer support interactions.

G. Device & Usage Information

When you access our Website, we may collect:

• IP address, browser type, device type, operating system, time zone, and approximate location derived from your IP address; and
• interaction information such as pages viewed, time spent, links clicked, referral URLs, and other usage analytics.

H. Cookies, Pixels, and Similar Technologies

We and our service providers may use cookies, pixels, and similar technologies to support Website functionality, security, analytics, and marketing as described in Section 3.

You may choose not to provide certain Personal Information, but some Services or features may not be available to you.

If you provide Personal Information about another person, you represent that you have authority to provide that information and permit us to use it in accordance with this Privacy Policy.

2) HOW DO WE COLLECT PERSONAL INFORMATION?

We and our service providers collect Personal Information in various ways, including:

• Directly from you, such as when you complete forms, create an account, request services, contact support, or complete a purchase.
• Automatically, such as through cookies and similar technologies when you use our Website.
• From service providers that assist us in operating our Services, including hosting, payment processing, customer support, security, and fulfillment services.
• From healthcare and fulfillment partners, where appropriate for non-clinical billing, customer support, order status, and fulfillment purposes.
• From affiliates or other partners, where applicable and consistent with this Privacy Policy.

3) HOW DO WE USE COOKIES AND SIMILAR TECHNOLOGIES?

We may use cookies and similar technologies for functionality, security, analytics, and marketing.

A. Cookies

Cookies are small files stored by your browser. We may use cookies to:

• remember preferences and session settings;
• help you navigate and use our Website;
• understand how users interact with our Website;
• detect fraud and protect accounts; and
• support marketing and advertising, where used.

B. Pixel Tags (Web Beacons)

We may use pixel tags to:

• measure Website performance and marketing effectiveness;
• track whether emails are opened and links are clicked; and
• better understand usage patterns.

C. Analytics

We may use analytics tools, such as Google Analytics or similar services, to understand Website activity and improve our Services. These providers may collect information such as IP addresses, device identifiers, and browsing events.

D. Interest-Based and Targeted Advertising

We may use third-party advertising tools, including social media advertising platforms, analytics providers, and advertising partners that use cookies, pixels, and similar technologies to:

• measure the effectiveness of advertising campaigns;
• understand interactions with our Services; and
• deliver advertisements that may be relevant to your interests.

These third parties may collect information concerning your device, browser, and interactions with our Website and may use this information across different websites and platforms.

You may manage advertising preferences through your browser settings or privacy controls offered by the applicable advertising platforms.

4) DO WE COLLECT INFORMATION FROM CHILDREN UNDER 18?

Our Services are not intended for individuals under 18, and we do not knowingly collect Personal Information from individuals under 18.

If you believe an individual under 18 has provided Personal Information to us, please contact us using the information in Section 12.

5) WHAT DO WE DO WITH THE INFORMATION WE COLLECT?

We may use Personal Information for the following purposes:

A. Providing Our Services

• to provide access to the Website and its features;
• to process requests and transactions;
• to facilitate telehealth-related operational workflows, including consultation requests, eligibility, billing, support, and fulfillment; and
• to provide order and service status information.

B. Communicating With You

• to send service communications, such as order confirmations, account notices, and security alerts; and
• to provide support and respond to inquiries.

C. Analytics & Improvement

• to analyze Website performance and user interactions; and
• to fix bugs, improve usability, and develop or improve features.

D. Marketing & Promotional Purposes (Where Permitted)

• to send promotional communications where permitted; and
• to deliver relevant offers and measure campaign performance.

We do not use clinical medical records maintained by Provider Groups for Lunera Health’s marketing purposes.

E. Security, Fraud Prevention & Compliance

• to protect our users and Services against fraud, abuse, or security risks; and
• to comply with applicable legal obligations and enforce our Terms.

F. Legal Rights & Business Transactions

• to comply with lawful requests and legal processes; and
• in connection with a merger, acquisition, financing, reorganization, or sale of assets.

G. De-Identified and Aggregated Information

We may create aggregated or de-identified information that cannot reasonably identify you and use it for analytics, improvement, and business purposes.

6) WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

We may disclose Personal Information to the following categories of recipients:

A. Service Providers

We may disclose Personal Information to vendors that help us operate our Services, such as hosting, payment processing, customer support, security, communications, analytics, and related technology providers.

These providers may use information only as permitted in connection with the services they provide and subject to applicable contractual and legal requirements.

B. Licensed Providers / Provider Groups

We may provide information necessary to licensed healthcare professionals and independent Provider Groups to initiate or facilitate healthcare services you request.

Once information is received or created by a Provider Group in connection with your clinical care, that Provider Group’s privacy practices and applicable Notice of Privacy Practices govern its handling of clinical information.

C. Pharmacies, Labs, and Fulfillment Partners

Where applicable, information necessary to coordinate prescription fulfillment, laboratory services, diagnostics, shipping, or other requested services may be provided to the appropriate third parties.

D. Advertising & Analytics Partners (If Used)

We may disclose limited information, such as device identifiers, cookie identifiers, or Website event information, to analytics and advertising partners to measure performance and provide advertising consistent with your choices.

E. Legal and Safety

We may disclose Personal Information when necessary to comply with applicable law or legal process, protect our rights, prevent fraud, or protect the safety of users or others.

F. Business Transfers

If Lunera Health is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, Personal Information may be transferred as part of that transaction.

We do not sell clinical medical records or PHI maintained by Provider Groups.

We do not knowingly sell Personal Information of individuals under 18.

We do not sell your Personal Information for monetary compensation.

However, certain disclosures through cookies, analytics services, and advertising technologies may constitute “sharing” under certain state privacy laws. You may request to opt out of such sharing by contacting us using the information below.

7) DOES THIS PRIVACY POLICY APPLY TO OTHER WEBSITES?

Our Services may contain links to websites or services operated by third parties.

This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. You should review the privacy policies of third-party websites and services you use.

8) HOW DO WE SECURE THE INFORMATION WE COLLECT?

We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information.

However, no method of transmission or storage can be guaranteed to be completely secure.

If you believe your interaction with us is no longer secure, please contact us immediately using the information in Section 12.

9) YOUR CHOICES REGARDING MARKETING AND COMMUNICATIONS

A. Email Marketing

You may opt out of marketing emails by using the “unsubscribe” link provided in the email.

B. Text Messages

Where applicable, you may opt out of marketing text messages by replying “STOP.”

C. Service Communications

Even if you opt out of marketing communications, we may continue to send important transactional or service-related communications, such as account notices, security alerts, receipts, order information, and other communications necessary to provide requested Services.

D. Cookies & Interest-Based Ads

You may manage cookies through your browser settings. Certain advertising platforms and networks may also provide their own privacy controls and opt-out tools.

10) CAN YOU UPDATE OR CORRECT YOUR INFORMATION?

You may contact us to request updates or corrections to Personal Information maintained by Lunera Health. We will respond consistent with applicable law and operational requirements.

Requests concerning clinical medical records maintained by a Provider Group may need to be submitted to the applicable Provider Group. We can direct you to the appropriate contact where necessary.

Email: [INSERT LUNERA HEALTH EMAIL]

11) CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time.

The “Last Updated” date at the top indicates when this Privacy Policy was most recently revised. Changes become effective when posted, unless otherwise required by applicable law.

12) CONTACT US:

If you have questions about this Privacy Policy or Lunera Health’s privacy practices, please contact:

Lunera Health LLC
7901 4th Street N, Suite 300 St. Petersburg, FL 33702
Email:Info@inbox.joinlunera.com
Phone: +1 (645) 231-1405
Website: https://joinlunera.com/