Consumer Health Data Privacy Policy

Introduction

Bespoke (“Bespoke,” “we,” or “us”) owns and operates this website, the partner and prescriber portals, and the services it provides through partner brands (collectively, the “Service”). Your use of the Service is subject to our Privacy Policy unless stated otherwise. Capitalized terms not defined here have the meanings given in our Terms and Conditions.

This Consumer Health Data Privacy Policy applies to the extent required by applicable state law to consumer health data (“Consumer Health Data”) as defined by that law. It does not apply to protected health information subject to the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which is governed by our Privacy Policy. This policy supplements our Privacy Policy. If they conflict, this policy applies to the extent it is consistent with applicable state law.

Collection of Consumer Health Data

The Consumer Health Data we collect depends on how you interact with us, the services you use, and the choices you make. We collect it from you directly, automatically, from third-party sources, and by inferring or generating it from other data.

Consumer Health Data you provide

• Name and contact information, such as your name, email address, phone number, and billing and shipping addresses.
• Demographic information, such as your gender, date of birth, and zip code.
• Payment information, such as card number and other payment details.
• Account information, such as a username and password or other credentials that allow access to an account.
• Marketing information, such as your preferences for receiving marketing communications.
• Content, such as photographs, documents, and other files you upload, and messages you send to your provider or to us.
• Government-issued identifiers, such as a driver’s license number, including images of identification cards where required to verify your identity.
• Health information, such as information about your physical or mental health status.
• Sexual and reproductive health information, where relevant to the treatment you request.

Consumer Health Data we collect automatically

• Identifiers and device information. Our servers log your IP address and information about your device, browser, and software, including type, version, language, and settings. As described in our Cookie Policy, the Service stores and retrieves cookie identifiers.
• Location data. We may derive general location from your IP address, and we use the address you provide to confirm you are in a state where we provide services.
• Usage data. We log your activity on the Service, including the referring URL, pages viewed, time spent, and access times. Some of this may relate to browsing health-related pages.

Consumer Health Data we create, infer, or generate

We may create, infer, or generate Consumer Health Data from other data we collect, including by automated means.

Consumer Health Data from third-party sources

• Partner brands through which you request treatment.
• Pharmacies that fill your prescriptions, such as shipping and delivery status.
• Service providers that collect or provide data on our behalf.
• Corporate affiliates, if any.
• Publicly available sources, such as government databases.

Use of Consumer Health Data

Purposes of use and the categories of Consumer Health Data used

Purpose of use	Categories of Consumer Health Data
Service delivery. To provide the Service and operate our business, including arranging consultations, sending prescriptions to pharmacies, confirming your location, billing, administering your account, securing our systems, detecting fraud, providing support, communicating with you, verifying your identity, complying with legal obligations, and enforcing our rights.	Contact information, demographic data, payment information, content and files, identifiers and device information, location data, usage data, inferences, government ID, account information, health data, and sexual and reproductive health information.
Improvement and development. To develop, test, and improve the Service, and to analyze traffic and use of the Service.	Identifiers and device information, usage data, inferences, and de-identified health data.
Aggregation and de-identification. We may create aggregated or de-identified data by removing information that identifies you, and will not attempt to re-identify it except as required by law. We may use and disclose this data.	Any of the categories above, once de-identified.
Marketing. To tell you about services, offers, and other information, subject to your choices and consent where required.	Contact information, identifiers and device information, and usage data.

Sharing Consumer Health Data

We may share Consumer Health Data with your consent, as needed to provide the services you requested, or as permitted or required by law. For example, we may share it with:

• Providers and pharmacies involved in your care, and the partner brand you used, so they can deliver the service you requested.
• Service providers that process data on our behalf under contract.
• Affiliates, where we share common systems or access helps us provide our services.
• Legal and law enforcement, when we believe it is necessary to comply with law or valid legal process, or to protect our customers or the rights or property of ourselves or others.

Your Consumer Health Data rights

Depending on your state of residence, you may have the following rights, subject to certain limitations:

• Withdraw consent. Where we rely on your consent to collect or share your Consumer Health Data, you can withdraw it for future collection or sharing.
• Access and confirm. You can ask us to confirm whether we have collected, shared, or sold your Consumer Health Data, request a copy, and receive a list of the third parties and affiliates with whom we shared or sold it.
• Correction. You can ask us to correct inaccurate Consumer Health Data.
• Deletion. You can ask us to delete your Consumer Health Data.
• Opt out of sale or sharing and targeted advertising. You can opt out of the sale or sharing of your personal information and of targeted advertising.
• Limit use of sensitive information. You can ask us to limit our use of your sensitive personal information to what is necessary to provide the Service.
• Appeal. You can appeal our decision to deny a request. We will tell you how when we respond.

To opt out or limit use in this browser, use Your Privacy Choices. We also honor the Global Privacy Control signal. To make any other request, email support@bespokeprescriptions.com.

We may need to verify your identity before processing a request, usually by asking you to confirm information we already have on file. If we cannot verify you that way, we may ask for additional information, such as government identification, which we will use only to verify your identity and for security and fraud prevention.

We need certain Consumer Health Data to provide the Service. If you ask us to delete it, or withdraw consent for its collection or sharing, we may not be able to provide the Service or some of its features.

Changes to this policy

We may modify this Consumer Health Data Privacy Policy at any time. If we make material changes, we will update the date above and post the revised policy on the Service or notify you by other appropriate means. Changes take effect when posted unless stated otherwise.