Privacy Policy

1. Scope

This Privacy Policy applies to:

• thryveclinic.com and any Thryve-branded landing pages (including /get-started and /memberships)
• The Health Vault and patient portal (app.thryveclinic.com)
• Patient Dashboard
• Provider and care-team portals
• Online Checkout
• Membership Portal
• Telemedicine consultations
• Diagnostic lab ordering and results delivery
• Mobile phlebotomy scheduling and home collection visits
• Membership enrollment and billing, and one-time purchases such as the Comprehensive Health Assessment or a standalone telehealth consultation
• Customer support (chat, email, phone, SMS)
• Marketing communications, including email and SMS

This Policy does not apply to third-party websites, apps, or services we link to or integrate with, including any third-party scheduling, payment, or analytics tools, which maintain their own privacy practices.

2. Information We Collect

Identity and contact information: name, email, phone number, mailing and service address, date of birth, gender, emergency contact.

Health information: medical and family history, symptoms, medications, allergies, lifestyle and intake questionnaire responses, biomarker and laboratory test results, provider notes, diagnoses, and care plans. We may also collect medical records, laboratory reports, imaging reports, prescriptions, referrals, insurance documents, and other health-related files that you choose to upload to your secure Health Vault.

Phlebotomy and scheduling information: home address and access details needed to dispatch a mobile phlebotomist, appointment preferences, and visit notes.

Account information: username, encrypted password, login activity, device and browser information, IP address.

Payment and membership information: billing address and membership tier; card details are collected and processed by our PCI-compliant payment processors; Thryve does not store full card numbers.

Communications: messages you send to support or providers, survey responses, and records of your marketing preferences (including SMS opt-in/opt-out status).

Marketing and advertising data: information generated when you interact with our ads or website, such as pages visited, referral source, and advertising interaction data, collected through analytics and advertising technologies, including services such as Google Analytics, Meta advertising tools, or similar providers (see Section 6).

3. How We Use Your Information

We use your information to:

• Schedule and coordinate mobile phlebotomy visits and lab testing
• Deliver lab results and generate biomarker insights in your Health Vault
• Facilitate telemedicine consultations with our physicians
• Track your health data longitudinally and personalize care recommendations
• Process membership enrollment, billing, and renewals
• Respond to support requests
• Send appointment reminders and service-related communications
• Send marketing communications (email and SMS) where you've consented
• Improve our website, funnel, and services, including through analytics
• Detect fraud, secure our systems, and comply with legal obligations

Where permitted by applicable law, we may use de-identified or aggregated information to improve our services, develop new features, perform analytics, and support internal research and quality improvement activities.

4. Artificial Intelligence Features

Certain features of the Services may use artificial intelligence ("AI") to assist in organizing health information, generating summaries, supporting clinical documentation, or providing educational wellness insights. AI is used solely as a support tool and does not replace the independent medical judgment of licensed healthcare professionals. Clinical decisions, diagnoses, treatment recommendations, and care plans remain the responsibility of your healthcare provider. AI outputs may occasionally contain inaccuracies or incomplete information and should always be reviewed in conjunction with your healthcare provider's professional judgment. We may use artificial intelligence technologies provided by carefully selected third-party service providers to deliver certain features of the Services. These providers are contractually required to protect information in accordance with applicable law and our agreements with them, where applicable. We do not use identifiable protected health information to train public AI models without appropriate authorization or as otherwise permitted by law.

5. Sharing Your Information

We share information with:

• Licensed physicians and clinical staff involved in your care
• Our diagnostic lab and mobile phlebotomy personnel
• Scheduling platforms, cloud hosting providers, payment processors, communication providers, analytics providers, laboratory partners, healthcare providers, pharmacies (where applicable), shipping and fulfillment providers (for example, to deliver prescribed medications to your address), and other healthcare service providers involved in delivering requested services
• Business associates who perform services on our behalf under appropriate agreements
• Government or law enforcement authorities when legally required
• Professional advisors such as attorneys and auditors

Thryve does not sell your personal information or protected health information to third parties. We do not share your personal information with third parties for their own independent marketing purposes without your consent. We do not share or sell your mobile phone number to third parties or affiliates for marketing or promotional purposes.

Business Transfers. We may transfer information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or other corporate transaction, subject to applicable law. Any successor entity will be required to honor this Privacy Policy or provide notice of any material changes as required by applicable law.

6. Cookies, Analytics, and Advertising

We use cookies and similar technologies to keep you signed in, remember preferences, and understand site performance. We use analytics and advertising tools, including Google Analytics and Meta (Facebook/Instagram) advertising tools, to measure ad performance and understand how visitors move through our site and booking funnel. These tools may use cookies or pixels to track interactions with our ads across sessions.

We may also use cookies, referral codes, and similar technologies to measure the effectiveness of affiliate and referral programs. Essential cookies are required for certain portions of the Services to function properly.

You can control cookies through your browser settings, opt out of Google Analytics using Google's opt-out browser add-on, and manage ad preferences through Meta's ad settings or the Digital Advertising Alliance's opt-out tool at optout.aboutads.info. Our website does not currently respond to browser "Do Not Track" signals. Where required by applicable law, we will obtain your consent before using non-essential cookies or similar technologies.

7. HIPAA

Thryve handles Protected Health Information ("PHI") in accordance with the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), where applicable, and other applicable healthcare privacy laws. Your care team may also provide a separate Notice of Privacy Practices describing how your PHI is used and disclosed; if there is a conflict between that Notice and this Policy, the Notice of Privacy Practices governs with respect to PHI.

8. Marketing Communications, Including SMS

With your consent or as otherwise permitted by law, we may send educational content, membership information, promotional offers, and appointment or health reminders by email and SMS.

Email: You may unsubscribe at any time using the link in any marketing email.

SMS: By opting in, you agree to receive recurring marketing and appointment-related text messages at the number provided. Message and data rates may apply, and message frequency varies. Consent to receive SMS is not a condition of purchasing any service. You may opt out at any time by replying STOP, and you can get help by replying HELP. We do not share or sell your mobile phone number to third parties or affiliates for their own marketing or promotional purposes.

Operational communications related to your care, appointments, or account (such as lab results being ready, or a phlebotomist confirming a visit) may continue even if you opt out of marketing communications, as these are necessary to deliver the services you've requested.

These SMS notifications may reference your appointment details, lab order status, and general care plan updates. We do not include sensitive lab results or detailed clinical information in message content; full results and details are only accessible after you securely log in to your Thryve Health Vault account.

9. Data Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest where appropriate, role-based access controls, multi-factor authentication for administrative access, security monitoring, and audit logging. We regularly review and update our administrative, technical, and physical safeguards to help protect personal information against unauthorized access, alteration, disclosure, or destruction. While we strive to protect your information, no system connected to the internet can be guaranteed to be 100% secure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Data Retention

We retain information as long as necessary to provide services, comply with legal and medical recordkeeping obligations, resolve disputes, and enforce agreements. Retention periods vary depending on applicable federal and state law, including the states in which we operate (currently Texas and South Carolina). Upon expiration of the applicable retention period, we will securely delete or de-identify information unless a longer retention period is required by law.

11. Your Privacy Rights

Subject to applicable law, you may have the right to access your information, request correction of inaccurate information, request deletion where permitted by applicable law, obtain a copy of your data, restrict certain processing, withdraw consent, and opt out of marketing. To exercise these rights, contact us using the information in Section 14.

Notice to Texas and South Carolina Residents

We do not sell personal information and do not share personal information with third parties for their own direct marketing without your consent. If applicable state law grants you additional specific rights, you may exercise them by contacting us as described below.

Notice to California Residents

If you are a California resident, you may request information about our disclosure of personal information to third parties for direct marketing purposes under California Civil Code Sections 1798.83–1798.84. Submit requests to the contact information in Section 14.

Other State Privacy Laws

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws. We will honor those rights where required by law.

12. Children's Privacy

Thryve's services are intended for adults. Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 without parental consent. Where applicable law permits use by minors under the supervision of a parent, legal guardian, or healthcare provider, the parent or guardian is responsible for creating and managing the relevant account.

13. Third-Party Services

Our platform integrates with third-party services, including laboratories, payment processors, cloud hosting providers, communication providers, analytics providers, and other service providers. These third parties maintain their own privacy policies and are responsible for their own data handling practices, and we encourage you to review their policies.

14. Contact Us

If you believe your privacy rights have been violated, please contact our Privacy Officer at support@thryveclinic.com.

If you have concerns about how we handle your personal information or believe we have not complied with this Privacy Policy, please contact us using the information above. We will review your request and respond in accordance with applicable law.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be reflected in an updated "Last Updated" date, with additional notice provided through our website or other appropriate channels where required. Continued use of our services after changes take effect constitutes acceptance of the updated Policy.

This Privacy Policy shall be interpreted in accordance with applicable United States federal law and the laws of the State of Wyoming, except where another jurisdiction's law is required to apply.

If you have questions regarding this Privacy Policy, please contact us using the information above.

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