Truemed Consumer Health Data Privacy Policy

As described further in our Privacy Policy, you may, while using certain components of Truemed’s services (“Services”), provide information that may be protected under laws that govern the collection, use, and disclosure of personal medical information. In connection with the Services, Truemed contracts with ApolloTechnologies, Inc. doing business as OpenLoop and its affiliated entities (the “Medical Group”) to facilitate online telehealth services provided by licensed practitioners from the Medical Group (each a “Provider”) to Truemed customers who are their patients.

The Medical Group and the Providers may be a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations (collectively and as amended, “HIPAA”). Truemed under some circumstances may be a “business associate” of the Medical Group and/or its affiliates or Providers. To the extent that Truemed is acting as a “business associate,” Truemed may be subject to certain provisions of HIPAA with respect to “protected health information” (“PHI,” as defined under HIPAA) that Truemed collects, uses, or discloses on behalf of the Medical Group or its Providers.

PHI that is collected, used, and disclosed by Truemed on behalf of the Medical Group is not considered “CHD” under this CHD Policy. An example of PHI that Truemed collects on behalf of the Medical Group includes your responses to the health questionnaire in Truemed’s qualification survey. This Consumer Health Data Policy applies only to other personal medical information that is defined as CHD under Applicable Laws.

Depending on how you interact with the Services and Applicable Laws, we may collect the following categories of CHD, as broadly defined in the Applicable Laws:

• Purchase of products or services to cure, treat, mitigate, or prevent identified medical conditions from Truemed’s merchant partners through Truemed’s services

• Data that identifies a consumer seeking health care services, e.g., by utilizing Truemed’s Services.

• Other information that may be used to infer, derive, or extrapolate data related to the above or other health information.

As described further in our Privacy Policy, we may collect information, which may include CHD from the following sources: (1) directly from you; (2) automatically through your use of the Services; and (3) through our merchant partners and other third-party sources.

We describe the purposes for collection and use of CHD in the “How Truemed uses your Personal Data” section of our Privacy Policy. As further described there and subject to applicable law, we may collect and use CHD as directed by you or with your consent, or (1) to provide and manage Truemed’s Services; (2) to analyze and improve the Services; (3) for advertising and marketing; and (4) for legal purposes, such as to comply with laws or to establish, exercise, or defend our legal rights.

We may share each of the categories of CHD described above for business purposes to the categories of entities described in the “How Truemed shares your Personal Data” section of our Privacy Policy. As further described in our Privacy Policy and subject to Applicable Laws, we may share the categories of CHD:

• to deliver products and services to you, including to complete any transactions initiated by you;

• to ensure a consistent level of service across our products and services;

• to enhance our products, services, and your customer experience;

• with your consent, such as disclosures for certain advertising or promotional efforts, including allowing third parties to collect CHD across our Websites;

• to protect Truemed and others, including to enforce our Terms of Use, Privacy Policy, or other contracts with you, and for fraud prevention;

• to comply with our legal obligations; and

• in connection with any negotiation or completed acquisition, merger, or purchase involving our business assets.

We reserve the right to create aggregated and/or de-identified data from the information we collect through the Services and our use or disclosure of such aggregated or de-identified data is in our discretion.

As further described in our Privacy Policy, and subject to applicable law (e.g. subject to your consent in certain situations), we may share CHD with the following categories of third parties and affiliates:

• Health care providers;

• Service providers;

• Advertising networks;

• Merchant and joint product marketing partners;

• For the protection of Truemed and others (e.g. to governmental or regulatory agencies);

• For legal purposes (e.g. to governmental entities in response to legal process);

• As necessary for business transfers; and

• At your direction or with your consent (such as sharing with other users/public if you post in public forums or interact with other users).

Subject to exceptions, Applicable Laws permit you certain rights to CHD. Depending on your jurisdiction, this may include requests (1) to confirm whether Truemed is collecting, sharing or selling your CHD; (2) to access your CHD; (3) to delete your CHD; (4) to withdraw your consent to the collection or sharing of your CHD, and (5) to correct inaccuracies in your CHD. You can seek to exercise these rights by contacting us at privacy@truemed.com. Depending on the nature of your request, we may contact you for further information if appropriate to authenticate your identity.

If we deny your request in whole or in part, you may appeal that decision by notifying us. If you are a resident of Washington and your appeal is denied, you can contact the Washington State Attorney General at www.atg.wa.gov/file-complaint. If you are a resident of Nevada and your appeal is denied, you can contact the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/. If you are a resident of Connecticut and your appeal is denied, you can contact the Connecticut Attorney General at https://www.dir.ct.gov/ag/complaint/e-complaint.aspx.

We reserve the right to change this CHD Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised CHD Policy accessible through the Services, so you should review it periodically. The date this CHD Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the CHD Policy. If we make a material change to the CHD Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites or Apps after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this CHD Policy.

If you have any questions about this CHD Policy or Truemed’s privacy practices, please contact us at privacy@truemed.com.

This CHD Policy was last updated on 02/20/2025 and is deemed effective as of this date.