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CONSUMER HEALTH DATA PRIVACY POLICY

VitalPeak Consumer Health Data Privacy Policy

VitalPeak, Inc.
Last Updated: December 16, 2025

1. Introduction

VitalPeak, Inc. and its subsidiaries or affiliates (“VitalPeak,” “we,” “us”) operate our websites and any VitalPeak mobile applications (collectively, the “Platform”). Your access to and use of the Platform and related features, content, products, and services (collectively, the “Service”) are generally governed by our Privacy Policy unless stated otherwise.

This Consumer Health Data Privacy Policy (“CHD Policy”) applies to the extent required by applicable state law to “consumer health data” or similar categories of health-related data (“Consumer Health Data”), as defined by those laws.

Important: HIPAA / PHI

This CHD Policy does not apply to Protected Health Information (“PHI”) that is subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). PHI is governed by the applicable Notice of Privacy Practices for the medical provider or medical group providing your clinical care.

This CHD Policy supplements our Privacy Policy. If there is a conflict, this CHD Policy controls to the extent required by applicable law.

2. What We Mean by “Consumer Health Data”

“Consumer Health Data” generally includes information that identifies you (or could reasonably be linked to you) and relates to your past, present, or future physical or mental health status, healthcare services, or health conditions, as defined by applicable state law.

The specific Consumer Health Data we collect depends on how you interact with the Service and what options you choose.

3. How We Collect Consumer Health Data

We may collect Consumer Health Data in four main ways:

  1. You provide it directly

  2. We collect it automatically through cookies and similar technologies

  3. We receive it from third parties you interact with or authorize

  4. We infer or generate it from other information (e.g., likely preferences)

4. Categories of Consumer Health Data We May Collect

A. Consumer Health Data you provide

Examples may include:

  • Contact information: name, email, phone number, shipping/billing address

  • Demographic information: date of birth, zip code, and other profile information you choose to provide

  • Account information: username and password or other login credentials

  • Payment information: payment card details (typically handled by our payment processor), transaction history

  • Communications and content: messages you send us, photos or files you upload (e.g., for identity verification or service requests)

  • Government ID information: ID numbers or images of identification cards (where required for verification or compliance)

  • Health-related information: information about hair loss, symptoms, goals, relevant medical history, medications, allergies, or other health information you submit through intake forms or support channels

  • Sensitive health-related information (if you provide it): information that certain state laws may treat as sensitive (for example, details that may relate to sexual health or other sensitive topics)

Note: If you are receiving clinical care through a Provider/Medical Group, health information collected for clinical care may be governed by HIPAA and the applicable Notice of Privacy Practices.

B. Consumer Health Data we collect automatically

When you use the Service, we may automatically collect:

  • Identifiers and device information: IP address, device identifiers, browser type, OS, language settings

  • General location information: approximate location derived from IP address (and, if enabled, device location features in an app)

  • Usage data: pages visited, time on site, clicks, referral URLs, and similar activity. In some cases, this may indicate interest in health-related topics.

C. Consumer Health Data we infer or generate

We may infer or generate information about your likely preferences or interests based on your activity (for example, whether you appear interested in certain hair loss education topics).

D. Consumer Health Data we obtain from third parties

We may receive Consumer Health Data from:

  • Service providers performing services on our behalf (analytics, customer support, fraud prevention)

  • Third-party accounts you connect (e.g., login providers or social platforms if you choose to connect them)

  • Co-marketing or advertising partners where permitted by law and based on your settings/consent

  • Public sources (limited cases)

5. How We Use Consumer Health Data

We use Consumer Health Data for purposes described in this CHD Policy, our Privacy Policy, or as otherwise disclosed to you. Examples include:

A. Service delivery and operations

To operate the Service, including:

  • creating and administering accounts

  • processing payments and fulfilling orders

  • verifying identity and confirming location (where required)

  • providing customer support

  • communicating about the Service (including reminders and service notices)

  • preventing fraud and securing systems

  • troubleshooting and debugging

  • complying with legal obligations and enforcing rights

B. Product improvement and development

To improve and develop the Service, including:

  • analyzing performance and user experience

  • testing and improving features

  • understanding what content is helpful

  • quality assurance and service optimization

C. Deidentification and aggregation

We may create deidentified or aggregated data from Consumer Health Data. We take steps to remove identifiers and do not attempt to reidentify the data except where legally required. We may use and share deidentified/aggregated data for lawful purposes.

D. Marketing and communications (where permitted)

To send communications about offers, updates, and content, and to measure the effectiveness of marketing—subject to applicable law and your choices/consents.

6. How We Share Consumer Health Data

We may share (as defined by applicable law) Consumer Health Data in the following circumstances:

A. With service providers

We share Consumer Health Data with vendors who help us operate the Service (e.g., hosting, analytics, support tools, payment processing, security). They are authorized to use data only to provide services to us and under contractual safeguards.

B. With Providers/Medical Groups and care partners (where applicable)

If you request clinical services, your information may be shared with Providers/Medical Groups and related partners (e.g., pharmacies, labs) to support the services you request and as permitted by law.

C. With affiliates

We may share Consumer Health Data within VitalPeak corporate affiliates where necessary to operate our business and provide the Service.

D. For legal and safety reasons

We may disclose Consumer Health Data when we believe it is necessary to comply with law, respond to legal process, protect rights and safety, investigate fraud, or enforce agreements.

E. With your consent

Where required, we will obtain your consent before sharing Consumer Health Data for certain purposes. You may withdraw consent as described below.

7. Your Consumer Health Data Rights

Depending on your state of residence, you may have rights regarding Consumer Health Data, which may include:

  • Withdraw consent (where we rely on consent for collection/sharing)

  • Access and confirm whether we collect/share Consumer Health Data and request a copy

  • Correction of inaccurate Consumer Health Data

  • Deletion of Consumer Health Data

  • List of third parties/affiliates with whom Consumer Health Data is shared (where required by law)

  • Appeal a denied request (where required)

How to exercise your rights

Submit a request by contacting:
Email: privacy@vitalpeak.com
Web form: [Insert “Privacy Request” URL if you have one]

We may need to verify your identity. If verification is not possible using information we already have, we may request additional information (including government ID). We will use verification information only for identity verification, security, and fraud prevention.

Important note

Some Consumer Health Data may be required to provide the Service. If you request deletion of required data or withdraw consent for future collection/sharing of required data, we may not be able to provide all or part of the Service.

8. Cookies and Tracking (Health-Related Implications)

Some cookies and similar technologies may collect data that could be considered Consumer Health Data under certain state laws (for example, browsing activity that indicates interest in health-related topics). You can manage cookies through our cookie preference tools (if available) and your browser/device settings. See our Privacy Policy for details.

9. Changes to This CHD Policy

We may update this CHD Policy from time to time. If we make material changes, we will update the “Last Updated” date and post the revised version on the Service. Your continued use of the Service after the effective date means this updated CHD Policy applies to your use.

DBA: VitalPeak Meds
119 Clifford St. Detroit, MI 48226
United States
support@vitalpeakmeds.com