Last Revised: August 18, 2026 This Privacy Policy describes how LIVV Care LLC, d/b/a 50 Stars Health ("50 Stars Health," "we," "us," or "our"), collects, uses, discloses, and protects information when you access or use the 50 Stars Health website, applications, and related services (collectively, the "Platform"). This Privacy Policy should be read together with the 50 Stars Health Terms of Use governing access to and use of the Platform. By accessing the Platform, creating an account, submitting information, enrolling in services, completing a purchase, or otherwise using the Platform, you acknowledge that you have been provided this Privacy Policy and have had an opportunity to review it. This Privacy Policy describes our data practices; where applicable law requires consent or authorization for a particular use or disclosure, 50 Stars Health will obtain it separately or through the applicable Platform workflow. 1. ROLE OF THE 50 STARS HEALTH PLATFORM 50 Stars Health operates a technology platform that facilitates connections between users and independent, state-licensed healthcare providers ("Providers") and licensed pharmacies. 50 Stars Health does not: - Practice medicine - Practice pharmacy - Provide medical advice - Control clinical decision-making - Diagnose medical conditions - Determine whether prescriptions are issued - Manufacture, compound, dispense, or ship medications Medical services are provided solely by independent healthcare Providers, and medications are dispensed by licensed pharmacies operating independently in their professional and dispensing functions. 50 Stars Health does not direct or control the professional judgment of Providers or pharmacies and is not responsible for their independent clinical or pharmacy decisions. Use of the Platform does not create a provider-patient relationship with 50 Stars Health. Medical records relating to professional healthcare services are maintained by or on behalf of the treating Provider and, where applicable, by pharmacies in accordance with applicable law. 50 Stars Health may host, process, transmit, or maintain such information on behalf of Providers or pharmacies when acting as a service provider or business associate. Depending on the function being performed and the information involved, 50 Stars Health may act in its own capacity as a technology platform operator or as a service provider or business associate to a healthcare Provider or other HIPAA-regulated entity. Medication Images and Illustrations Images or illustrations of medications, packaging, or labels displayed on the Platform are provided for informational and illustrative purposes only. Any medication that may be prescribed through a healthcare provider using the Platform will be compounded or dispensed by a licensed pharmacy in accordance with applicable pharmacy laws and regulations. The appearance, labeling, packaging, and pharmacy identification on the medication you receive may differ from any images displayed on the Platform. 1.1 HIPAA, Protected Health Information, and Other Health Data Certain health information that 50 Stars Health creates, receives, maintains, or transmits on behalf of a HIPAA-covered healthcare Provider or other regulated entity may constitute protected health information ("PHI"). When 50 Stars Health acts as a HIPAA business associate, its use and disclosure of PHI is governed by HIPAA, applicable business associate agreements, and other applicable law. The treating Provider's Notice of Privacy Practices describes how that Provider may use and disclose PHI. Other health-related or consumer health information collected by 50 Stars Health in its own capacity may not be PHI under HIPAA. Such information remains subject to this Privacy Policy and to applicable federal and state privacy and consumer-health-data laws. Nothing in this Privacy Policy expands or reduces rights that apply to PHI under HIPAA. 2. INFORMATION WE COLLECT We may collect several categories of personal information. 50 Stars Health collects only the personal information reasonably necessary to operate the Platform, provide requested services, comply with legal obligations, and maintain system security. 2.1 Personal Identifiers Information that identifies or can reasonably be linked to an individual, including: - Full name - Date of birth - Email address - Phone number - Mailing or shipping address - Billing address - Account credentials - Government-issued identification when required for verification 2.2 Health-Related Information When you use the Platform to seek telehealth services, you may provide information including: - Medical history - Symptoms - Current medications - Allergies - Prior diagnoses - Treatment history - Telehealth questionnaire responses - Provider communications - Prescription information Healthcare providers may collect and maintain medical records consistent with applicable healthcare regulations. 2.3 Payment Information When you purchase services or enroll in subscriptions, payment information may be collected, including: - Payment card information - Billing address - Transaction records Payment processing is typically handled by third-party payment processors, and 50 Stars Health does not store full payment card numbers. 2.4 Device and Technical Information We may automatically collect certain information about your device and interaction with the Platform, including: - IP address - Device identifiers - Browser type - Operating system - Internet service provider - Timestamps and usage activity - Pages visited and navigation patterns 2.5 Geolocation Information We may collect general location information based on IP address or device data. Location information may be used to verify that telehealth services are provided in jurisdictions where healthcare providers are licensed. 2.6 Cookies and Tracking Technologies The Platform may use: - Cookies - Pixels - Web beacons - Local storage technologies - Analytics tools These technologies help maintain platform functionality, remember user preferences, analyze usage, and improve services. 3. SOURCES OF INFORMATION Information may be collected from several sources, including: - Information you provide directly through the Platform - Healthcare providers using the Platform - Pharmacies involved in prescription fulfillment - Service providers and payment processors - Identity verification vendors - Automated technologies such as cookies and analytics tools 4. CATEGORIES OF PERSONAL INFORMATION COLLECTED Identifiers (name, email, phone number, DOB) — collected from User — for account creation and verification. Health Information (medical history, medications, symptoms) — collected from User / Providers — for telehealth services. Commercial Information (payment history, subscriptions) — collected from payment processors — for billing. Internet Activity (IP address, browsing activity) — collected via cookies / analytics — for platform performance. Geolocation Data (approximate location) — collected from device data — for licensing verification. Device Information (browser, OS, device ID) — collected from device — for security and analytics. 5. PURPOSES FOR PROCESSING INFORMATION We may process personal information for purposes including: - Providing and operating the Platform - Facilitating telehealth consultations with licensed healthcare providers - Transmitting prescriptions to licensed pharmacies for fulfillment when authorized by a provider - Processing payments and managing subscriptions - Verifying identity and preventing fraud, unauthorized access, or misuse of the Platform - Communicating with users regarding services, accounts, prescriptions, and support inquiries - Coordinating prescription fulfillment and shipping - Improving platform functionality, security, and user experience - Conducting analytics and performance monitoring - Complying with legal, regulatory, and contractual obligations - Enforcing platform policies, agreements, and legal rights 6. SENSITIVE PERSONAL INFORMATION Certain information collected through the Platform may constitute Sensitive Personal Information, including: - Health information - Identity verification information - Precise or approximate geolocation data 50 Stars Health uses sensitive personal information only as reasonably necessary to provide requested services, facilitate care, fulfill user-directed transactions, verify identity or location, maintain security, comply with law, and carry out other purposes permitted by applicable law. We do not use sensitive health information for targeted advertising where prohibited by law. 7. HOW INFORMATION IS SHARED We may share information in the following circumstances. 7.1 Healthcare Providers Information you submit may be shared with independent licensed healthcare providers to facilitate telehealth consultations and treatment decisions. 7.2 Pharmacies If a provider issues a prescription, prescription information may be transmitted to a licensed pharmacy selected by the provider or patient for dispensing and fulfillment. The dispensing pharmacy is responsible for: - Prescription verification - Drug utilization review - Labeling and counseling - Regulatory compliance - Shipping and fulfillment 7.3 Service Providers We may share information with vendors that support Platform operations, including: - Payment processors - Cloud hosting providers - Analytics providers - Identity verification services - Communication service providers - Customer support platforms Service providers are required by contract or applicable law to safeguard personal information and to process it only for authorized purposes. Where a service provider handles PHI on behalf of 50 Stars Health in a HIPAA-regulated capacity, appropriate business associate or subcontractor terms are used as required by law. 7.4 Legal Compliance Information may be disclosed where necessary to: - Comply with applicable laws or regulations - Respond to subpoenas or court orders - Enforce legal rights or agreements - Protect user safety - Investigate fraud or misuse 7.5 Business Transfers If 50 Stars Health undergoes a merger, acquisition, restructuring, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to applicable privacy protections. 8. ELECTRONIC COMMUNICATIONS By using the Platform, you consent to receive communications electronically, including: - Email - Platform messaging - Telephone calls - SMS or MMS text messages These communications may relate to: - Account activity - Telehealth services - Prescription updates - Shipping notifications - Billing matters - Customer support Electronic communications may satisfy legal requirements that communications be provided in writing.
9. TEXT MESSAGE COMMUNICATIONS If you provide your mobile phone number and consent to receive text messages, 50 Stars Health may send messages including: - Appointment reminders - Prescription updates - Shipping notifications - Account alerts - Promotional messages where you opt in Message frequency varies. Message and data rates may apply. You may opt out of marketing messages by replying STOP. 50 Stars Health does not sell your mobile phone number. Your phone number may be shared with communication service providers acting on our behalf. 10. COOKIES AND TRACKING TECHNOLOGIES We use cookies and similar technologies for several purposes. Necessary Cookies: Required for essential platform functionality. Functional Cookies: Remember user preferences and improve usability. Analytics Cookies: Analyze platform usage and performance. Advertising and Marketing Technologies: May support marketing and advertising activities on public-facing portions of the Platform where permitted by applicable law and consistent with our privacy controls. You may manage cookie preferences through browser settings or cookie consent tools. 11. ANALYTICS AND ADVERTISING TECHNOLOGIES Public-facing portions of the Platform may use third-party analytics, advertising, or performance-measurement tools to understand usage, measure marketing effectiveness, and improve services. We do not intend for advertising technologies to receive PHI or sensitive health information from authenticated patient areas, medical intake forms, treatment communications, prescription workflows, or other areas where disclosure would be prohibited or inconsistent with applicable law or contractual obligations. - Pages visited - Time spent on pages - Referral sources - Device information Depending on the technology used, these tools may process limited device, referral, and usage information from public-facing pages. They are not authorized to use PHI or sensitive health information for their own advertising purposes. 12. AUTOMATED TECHNOLOGIES Certain platform functions may use automated technologies to assist with: - Identity verification - Fraud detection - System security monitoring These technologies support administrative processes and do not replace independent medical judgment by healthcare providers. 13. DATA SECURITY 50 Stars Health implements administrative, technical, and physical safeguards designed to protect personal information. Security measures may include: - Encryption in transit and at rest - Secure infrastructure - Role-based access controls - Authentication procedures - Monitoring and security testing However, no system can guarantee absolute security, and users acknowledge the inherent risks associated with internet-based communications. 14. DATA BREACH NOTIFICATION In the event of a data security incident involving personal information or health information, 50 Stars Health will investigate and provide notifications as required by applicable law. Depending on the nature of the information and 50 Stars Health's role, applicable requirements may include HIPAA breach-notification rules, the Federal Trade Commission Health Breach Notification Rule, and state data-breach or consumer-health-data laws. 15. DATA RETENTION We retain information for as long as necessary to: - Provide platform services - Comply with legal obligations - Resolve disputes - Enforce agreements Healthcare providers and pharmacies may retain medical records for periods required by applicable healthcare laws. The specific retention period for personal information may vary depending on the type of information, the purposes for which it was collected, regulatory requirements, and legitimate business needs. 16. DE-IDENTIFIED AND AGGREGATED DATA 50 Stars Health may create and use de-identified or aggregated information that cannot reasonably be used to identify individuals. Such information may be used for analytics, product improvement, research, and business operations. Where information has been de-identified, 50 Stars Health will maintain and use the information in de-identified form and will not attempt to re-identify individuals except as permitted by applicable law. De-identified information may also be combined with other data and may be shared with service providers, research partners, or business partners for lawful business purposes. 17. DO NOT TRACK SIGNALS Some web browsers transmit "Do Not Track" signals. Because there is no universally accepted standard for responding to such signals, the Platform does not currently respond to Do Not Track signals. 18. CROSS-BORDER DATA TRANSFERS Information collected through the Platform may be processed or stored in the United States. By using the Platform, you acknowledge that information may be transferred to jurisdictions with data protection laws that may differ from those of your jurisdiction. 19. STATE PRIVACY RIGHTS Residents of certain states may have rights regarding personal information or consumer health data. The particular rights available depend on your state of residence, the type of information involved, 50 Stars Health's role with respect to that information, and applicable exemptions, including exemptions for certain HIPAA-regulated information. - Right to Know / Access - Right to Delete - Right to Correct - Right to Data Portability - Right to Opt Out of targeted advertising - Right to Limit Use of Sensitive Information - Right to Non-Discrimination for exercising privacy rights Applicable laws may include those of California, Colorado, Connecticut, Virginia, Utah, Nevada, and other jurisdictions as applicable. Requests may require identity verification. Consumer Health Data Rights Certain states, including Washington and Nevada, regulate consumer health data that may fall outside HIPAA. Where such laws apply, 50 Stars Health will provide any required disclosures and obtain consent or authorization when required for collection, use, sharing, or other processing of consumer health data. Applicable rights may include access, deletion, withdrawal of consent, and information about categories of consumer health data and recipients. Requests may be submitted using the privacy contact information below. California Residents (CCPA / CPRA) If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA"), provides you with certain rights regarding your personal information. Subject to applicable exceptions, these rights may include: - Right to Know / Access – You may request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collecting or sharing it, and the categories of third parties with whom it has been shared. - Right to Delete – You may request that we delete personal information we have collected from you, subject to certain legal exceptions. - Right to Correct – You may request correction of inaccurate personal information maintained by us. - Right to Data Portability – You may request a copy of your personal information in a portable format. - Right to Opt Out of Sale or Sharing – California residents have the right to opt out of the "sale" or "sharing" of personal information as defined under California law. - Right to Limit Use of Sensitive Personal Information – California residents may request that we limit our use or disclosure of sensitive personal information where applicable. - Right to Non-Discrimination – We will not discriminate against you for exercising your privacy rights. California residents may also request certain information regarding disclosure of personal information to third parties for their direct marketing purposes pursuant to California Civil Code Section 1798.83. You may exercise these rights by contacting us at: privacy@50starshealth.com We may require verification of your identity before responding to a request. Authorized agents may submit requests on your behalf with proof of authorization. No Sale or Sharing of Personal Information 50 Stars Health does not sell personal information for monetary consideration. However, certain uses of cookies, analytics technologies, or advertising services may be considered "sharing" of personal information under certain state privacy laws. Where applicable law provides the right to opt out of such sharing, users may exercise that right by adjusting cookie preferences through our cookie consent tools or by contacting us at: privacy@50starshealth.com Certain health information maintained by healthcare providers or pharmacies may be governed by healthcare privacy laws such as HIPAA and may not be subject to all rights described in this section.
20. CHILDREN'S PRIVACY The Platform is not directed to children under age 13. Individuals who have reached the age of majority may use the Platform on their own behalf. A minor may access only those services expressly designated as available to minors, where permitted by applicable law, and only with the consent and involvement of a parent or legal guardian as required by applicable law and the treating Provider. 21. THIRD-PARTY SERVICES The Platform may contain links to third-party services or websites. 50 Stars Health is not responsible for the privacy practices of third parties. 22. CHANGES TO THIS PRIVACY POLICY 50 Stars Health may update this Privacy Policy periodically. Updated versions will be posted on the Platform with a revised effective date, and we will provide additional notice or obtain consent when required by applicable law. Where applicable law requires consent to a material change in our data practices, the change will not apply to covered information unless and until the required consent is obtained. 23. CONTACT INFORMATION If you have questions regarding this Privacy Policy or your personal information, please contact: 50 Stars Health Support Email: support@50starshealth.com Phone: 888-491-1070 Privacy requests may be submitted to: Privacy Officer privacy@50starshealth.com 24. RELATIONSHIP TO TERMS OF USE This Privacy Policy should be read together with the 50 Stars Health Terms of Use. In the event of a conflict between this Privacy Policy and the Terms of Use, the Terms of Use govern with respect to platform access, dispute resolution, and arbitration.
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