Privacy Policy

1. Who we are & what this covers

This Privacy Policy explains how myPromise, LLC ("Promise," "we," "us") handles information in connection with the website at mypromise.com (the "Site").

Promise is a technology platform. We are not a healthcare provider or a pharmacy, and we do not practice medicine or dispense medication. Clinical services are provided by independent, licensed clinicians in the WizDoc, LLC network, and prescriptions are filled by our partner pharmacy, PerfectRx. When you begin a visit, you are directed to the provider's secure platform, where your medical intake takes place under WizDoc's and PerfectRx's own privacy and HIPAA notices.

This policy covers the information Promise itself handles through the Site. It does not cover the separate ways WizDoc or PerfectRx handle your medical records — see Section 9.

2. Information we collect

Information you give us. Your name, email address, phone number, and the contents of any message you send us (for example, if you email our support team or ask a question). If you choose to create an account or make a purchase through our partners, you may provide additional details to them.

Waitlist signups. Some treatments are not yet available through Promise. If you join the waitlist on one of those pages, we store the email address you enter and which treatment page you submitted it from. That form does not ask for your name, your health history, or any other detail, and joining a waitlist is not a medical request — no prescription is issued from it.

Information we collect automatically. When you use the Site, we and our analytics providers automatically collect technical and usage data — such as your device type, browser, IP address, pages viewed, links clicked, and referring pages — through cookies and similar technologies. See Section 5.

Information from others. We may receive information about you from the WizDoc provider network, PerfectRx, and the service providers that help us operate — for example, confirmation that an order was placed or fulfilled, so we can support you.

Because Promise offers health-related products, some of the information above (including which product pages you view) may be considered health-related or "sensitive" information under certain laws. We treat it accordingly.

3. How we use your information

• Operate, maintain, and improve the Site and our services.
• Connect you with the WizDoc provider network and PerfectRx, and support your requests.
• Respond to your questions and provide customer support.
• Send you service messages and, where permitted, marketing communications (you can opt out at any time).
• Tell you if a treatment you joined a waitlist for becomes available, and gauge which treatments to prioritize. We do not use a waitlist address for any other purpose, and we do not add it to marketing lists.
• Measure and analyze how the Site is used so we can make it better.
• Protect the security and integrity of our services, prevent fraud, and comply with legal obligations.

4. How we share your information

We share information only as described here:

• Your provider and pharmacy. The WizDoc, LLC provider network and PerfectRx, so you can be evaluated, treated, and have prescriptions filled and shipped.
• Service providers. Vendors that perform services for us — such as website hosting, analytics, email/communications, and payment processing — under contracts that limit how they may use your information.
• Legal & safety. When required by law, subpoena, or legal process, or to protect the rights, safety, and property of Promise, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction.

We do not sell your personal information for money. Some state privacy laws define "sale" or "sharing" broadly to include certain uses of data for cross-context (targeted) advertising. To the extent we use advertising or analytics technologies that fall within those definitions, you can opt out — see Section 6 and Section 5.

5. Cookies, analytics & advertising

We use cookies and similar technologies to run the Site, remember your preferences, and understand how visitors use it.

We use Google Analytics to measure Site traffic and usage. Google Analytics sets cookies and collects information such as your IP address and browsing activity on our Site. You can learn about Google's practices at policies.google.com/privacy and opt out of Google Analytics using Google's browser opt-out add-on.

Your controls. Most browsers let you block or delete cookies. We also honor the Global Privacy Control (GPC) signal — if your browser or extension sends a GPC signal, we treat it as a request to opt out of "sale"/"sharing" of your information where applicable law requires.

6. Your privacy rights & choices

Depending on where you live, you may have some or all of the following rights:

• Know / access the personal information we hold about you.
• Correct inaccurate personal information.
• Delete personal information.
• Opt out of the "sale"/"sharing" of personal information and of targeted advertising.
• Appeal a decision we make about your request, where your state provides for appeals.

To exercise any of these rights, email us at privacy@mypromise.com. We will not discriminate against you for exercising your rights. We may need to verify your identity before responding, and you may use an authorized agent where the law allows.

7. State privacy rights

California. Under the CCPA/CPRA, California residents have the rights listed above, including the right to limit the use of "sensitive personal information." Health-related data is treated as sensitive personal information. You can submit requests at privacy@mypromise.com, and you may exercise your opt-out choices through the GPC signal described in Section 5. We do not sell personal information for money and do not knowingly sell or share the personal information of anyone under 16.

Other states. Residents of states with comprehensive privacy laws — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana — have similar rights to access, correct, delete, and opt out, and (except where a state does not provide it) to appeal. Use the same contact above to submit a request.

8. Consumer health data (Washington & Nevada)

Washington's My Health My Data Act and Nevada's consumer health data law give residents of those states specific rights regarding "consumer health data." Because those laws require a separate, dedicated notice, we describe those practices and rights in our Consumer Health Data Privacy Policy.

Joining a waitlist tells us you are interested in a specific treatment, which may itself be consumer health data under those laws. We store only your email address and the treatment page you submitted it from, use it only to contact you about that treatment, and never sell it or share it for advertising.

9. HIPAA & your provider's Notice of Privacy Practices

Promise (myPromise, LLC) is not a "covered entity" under the Health Insurance Portability and Accountability Act (HIPAA). Where we handle protected health information on behalf of the WizDoc, LLC provider network and PerfectRx, we do so as a business associate under a Business Associate Agreement (BAA) and protect that information consistent with our obligations under HIPAA.

Your medical records and the clinical handling of your protected health information are maintained by the WizDoc, LLC provider network and PerfectRx, who are the HIPAA-covered parties. Each maintains its own HIPAA Notice of Privacy Practices, which describes how your health information is used and disclosed and the rights you have over it. You will receive or can request these notices from your provider and pharmacy during your visit, and we will make them available here once provided.

10. Data security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption of data in transit (TLS) and access controls. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

11. Data retention

We keep personal information for as long as needed to provide our services, for the purposes described in this policy, and to meet legal, tax, and recordkeeping requirements. When it is no longer needed, we delete or de-identify it.

Waitlist signups are kept until the treatment becomes available and we have contacted you, or until you ask to be removed — whichever comes first. You can have your waitlist entry deleted at any time by emailing privacy@mypromise.com.

12. Children's privacy

The Site and our services are intended 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 us at privacy@mypromise.com and we will delete it.

13. Users outside the United States

Promise is intended for residents of the United States. The Site is not directed to individuals in the European Economic Area, the United Kingdom, or other regions, and we do not intend to offer services to them. If you access the Site from outside the United States, you do so on your own initiative.

14. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above, and, for material changes, we will provide a more prominent notice as required by law.

15. Contact us

Questions about this policy or your privacy? Reach us at:

myPromise, LLC
7135 E Camelback Rd, Suite 230
Scottsdale, AZ 85251
(480) 999-3519 · privacy@mypromise.com