VITLrx Privacy Policy

Effective Date: May 8, 2025

Welcome to VITL! VITLrx, Inc. (“Vital” “we” “us” or “our”) provides a platform connecting clinics, pharmacies, and other health care providers (“Providers”) and their patients (“Patients”) to enable the fulfillment of e-prescriptions, pharmacy management, and virtual care services (the “Services”). Patients and Providers may be referred to as “you” or “your” in this Privacy Policy.

Scope of this Privacy Policy

This Privacy Policy is not a binding contract. Rather, it describes the type of personal data VITLrx collects and how it collects, uses, shares, and protects that personal data. “Personal Data” may mean and include Personal Information, Sensitive Personal Information, and Protected Health Information (“PHI”), each as defined and identified below, and may be collected through our websites at https://www.vitlrx.com/ and www.patients.vitlrx.com (collectively, the “Site”), our mobile applications (“Apps”), and from Patients and Providers who register as End Users to receive Services.

If you desire to receive our Services, you must register as an “End User” and enter into our End User License Agreement (“EULA”). When you register as an End User, and create an “End User Account” you will be asked to provide certain Personal Information such as your name, email address, username, mailing address, and phone number, and to create a user login and password. As an End User, you may also disclose your own or a Patient’s PHI, as covered by the Health Insurance Portability and Privacy Act (“HIPAA”).

Providers maintain and provide their Patients with their own privacy notices pursuant to HIPAA. To the extent we receive PHI directly from a provider, we will have entered into separate agreements with that Provider as required by HIPAA and other applicable laws. To the extent you are a Patient End User, the EULA will contain the terms governing consents, rights, and benefits related to your Personal Data and PHI.

We may collect the following types of Personal Data with your knowledge and consent:

1. Personal Information (Contact): Name, email address, screen name, mailing address, and phone number.
2. Unique Identifiers: Driver’s license number of identification card number, NPI number, professional license number (NP, MD, etc.), and DEA (Drug Enforcement Administration) number, profile picture or other photographs.
3. Sensitive Personal information: Ethnicity, gender, marital status, and date of birth.
4. PHI: Past, present or future physical or mental health conditions and current health status, including allergies, weight, height, medication history, surgical history, social history, exercise, activity, sleep, diet, and payment for the provision of health care.
5. Financial Account Information: Credit card or debit card number, and bank account numbers and routing numbers.
6. Geolocation information (zip code, street address).
7. Contents of email, chat rooms, bulletin board postings, and texts.

You may voluntarily provide your personal data to us, with your full knowledge and consent, under any of the following methods:

• When you submit registration forms to activate your End User Account;
• When you order Services through our Site or Apps;
• When you communicate with us through emails or texts (IM and SMS); and
• When you call our telephone support number.

We use Personal Data through our platform to connect clinics, pharmacies, and End Users to us and to each other and to provide our Services to all of our End User including to:

• Communicate with Providers and Patients;
• Facilitate communications and services between Provider and Patient End Users, including enabling Providers to conduct clinical evaluations and enabling Patients to chat with their Providers;
• Gather geolocation data to identify a user’s locale to enhance our ability to provide Services and to enable Patient/Provider contact;
• Enable prescribers to browse pharmacy offerings and write prescriptions for their Patients;
• Enable End Users to pay for Services they purchase;
• Enable Patients to pay for their medical programming and view Provider instructions;
• Administer our business, provide, update and improve Services, and develop new Services;
• Anonymize data for further internal and external use in a manner that does not identify you;
• Enhance security and prevent fraud or illegal activity;
• Perform our contractual duties and obligations under separate contracts with our End Users;
• Ensure compliance with legal obligations under HIPAA, documentation of controlled substances for the DEA, and credentialling a physician to use our platform;
• Provide user support and customer service; and
• Perform market research and analytics.

We use third party services to process payments and to support our network and operating systems. Your Personal Data may be disclosed to payment processors (e.g., PandaDoc or Stripe) and to credit card processors and banks, but only to the extent necessary to complete your transaction or to support our business and our users. Our contracts with third parties, service providers, and contractors include terms that specify the purposes for which the Personal Data is collected and ensure that these parties provide comparable levels of privacy protection. These contracts stipulate that:

• Personal Data may only be processed for specified purposes.
• The third party must maintain the confidentiality and security of the Personal Data.
• The third party must notify us if they can no longer meet these standards.
• Personal Data will not be further disclosed except as required by law.

• We do not sell your Personal Data to third parties.
• Users may not import personal address books, contacts, or other information to our Site unless specifically required for use of our Site or to use or order Services.
• Personal Data is not made publicly available to any other users or third parties.
• We do not advertise on our Site.

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