1. Introduction

Guppie, LLC ("Guppie," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile health application and any related services (collectively, the "Service").

We understand the sensitive nature of health information and take our obligations under applicable privacy laws, including the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), seriously. Please read this Privacy Policy carefully. By using the Service, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

2. Information We Collect

We collect several types of information from and about users of our Service:

2.1 Personal Information

Personal information is information that identifies you as an individual. We may collect the following categories of personal information:

• Identity Information: Full name, date of birth, mailing address, email address, telephone number, and government-issued identification numbers (such as Social Security Number) when required for identity verification purposes.
• Account Information: Username, password, and security questions/answers.
• Billing Information: If you purchase a subscription, we may collect payment information, such as credit card or other financial account information.

2.2 Protected Health Information (PHI)

We collect and maintain protected health information, which includes:

• Health Records: Medical history, conditions, diagnoses, treatments, and procedures.
• Medication Information: Current and past medications, dosage, frequency, and prescription details.
• Provider Information: Healthcare providers' names, specialties, contact information, and appointment history.
• Insurance Information: Insurance carrier, policy numbers, and coverage details.
• Pharmacy Information: Preferred pharmacy locations and contact details.

2.3 Usage Data

We automatically collect certain information about your device and how you interact with the Service:

• Device Information: Device type, operating system, unique device identifiers, IP address, mobile network information, and browser type.
• Usage Information: How you use the Service, including features accessed, time spent, and actions taken.
• Log Data: Error reports, crash data, system activity, and the date and time of your request.

2.4 Location Data

With your consent, we may collect precise location data from your device to help you locate nearby pharmacies or healthcare facilities.

3. How We Collect Your Information

We collect information in the following ways:

3.1 Information You Provide to Us

We collect information that you provide directly when you:

• Create or update your account
• Fill out forms in the Service
• Upload or enter health records and medication information
• Communicate with us

3.2 Automatic Data Collection

We may use cookies, web beacons, and similar technologies to automatically collect certain information when you use the Service. You can control cookies through your browser settings and other tools.

3.3 Third-Party Sources

With your authorization, we may collect information about you from third parties, such as:

• Healthcare facilities
• Pharmacies

4. How We Use Your Information

We use your information for the following purposes:

4.1 Provide and Improve the Service

• Operate, maintain, and improve the Service
• Provide medication reminders
• Route prescriptions to pharmacies
• Manage your medical health records
• Provide information about potential drug-allergy interactions
• Customize and personalize your experience
• Respond to your requests and inquiries

4.2 Communications

• Send service-related communications
• Provide important alerts and notifications related to your health care
• Send marketing communications (with your consent and where permitted by law)

4.3 Research and Analytics

• Analyze usage patterns and trends
• Conduct research to improve health outcomes
• Generate aggregated, de-identified statistical data

4.4 Legal and Safety Purposes

• Comply with legal obligations
• Protect the rights, safety, and property of Guppie, our users, and others
• Prevent fraud or potentially illegal activities

5. How We Share Your Information

We may share your information in the following circumstances:

5.1 With Your Consent

• We will share your health information with trusted contacts that you explicitly designate within the Service.
• We will share your information with third parties when you direct us to do so, such as when routing prescriptions to pharmacies.

5.2 Service Providers

We may share your information with third-party service providers that perform services on our behalf, such as:

• Cloud storage providers
• Analytics providers
• Customer service and technical support providers
• Payment processors

All service providers are contractually obligated to use your information only as necessary to provide services to us and in compliance with applicable privacy laws, including HIPAA where applicable.

5.3 Business Transfers

If Guppie is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your information.

5.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.5 De-identified Information

We may use and share de-identified information (information that cannot reasonably identify you) for any lawful purpose, including research, analytics, and improving healthcare services.

6. Data Security

We implement appropriate technical, administrative, and physical safeguards to protect the confidentiality, integrity, and availability of your information, especially your protected health information. Our security measures include:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on privacy and security practices
• Business associate agreements with service providers who handle PHI

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information.

7. Data Retention

We will retain your information for as long as your account is active, as necessary to provide you with the Service, or as otherwise required for legal compliance purposes. When we no longer need personal information for the purposes for which we collected it, we will delete or anonymize it.

You may request that we delete your information at any time by contacting us, subject to certain exceptions where we are legally required to retain information.

8. Your Rights and Choices

8.1 Access and Update Your Information

You can access and update your personal information by logging into your account and using the settings functionality. If you cannot access certain information, please contact us for assistance.

8.2 Communication Preferences

You can opt out of receiving promotional emails from us by following the unsubscribe instructions in those emails. You may not opt out of service-related communications (such as account verification, medication reminders, changes/updates to features of the Service, technical and security notices).

8.3 HIPAA Rights

As a covered entity under HIPAA, we respect your rights regarding your protected health information, including:

• Right to Access: You have the right to access and obtain a copy of your PHI.
• Right to Amend: You have the right to request that we correct information that you believe is incorrect or incomplete.
• Right to an Accounting of Disclosures: You have the right to request an accounting of certain disclosures of your PHI.
• Right to Request Restrictions: You have the right to request restrictions on certain uses and disclosures of your PHI.
• Right to Request Confidential Communications: You have the right to request that we communicate with you about your health information in a certain way or at a certain location.
• Right to a Paper Copy of This Notice: You have the right to a paper copy of this Privacy Policy.

To exercise these rights, please contact us using the information provided at the end of this Privacy Policy.

8.4 Do Not Track

Some browsers feature a "Do Not Track" setting. Our Service does not currently respond to "Do Not Track" signals.

9. Children's Privacy

The Service is not directed to children under the age of 18. We do not knowingly collect personal information from children under 18 without parental consent. If you are a parent or guardian and believe we have collected information from your child without your consent, please contact us immediately.

If a child under 18 uses the Service, such use must be under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy and our Terms of Service.

10. International Users

The Service is designed for users in the United States and is governed by United States privacy laws. If you access the Service from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where our servers are located.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date. If we make material changes, we will provide notice through the Service or by other means, such as email. Your continued use of the Service after the changes have been made will constitute your acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

13. California Privacy Rights

California residents may have additional rights regarding their personal information under California privacy laws. For more information about these rights and how to exercise them, please contact us using the information provided above.

14. HIPAA Notice of Privacy Practices

This Privacy Policy serves as our Notice of Privacy Practices under HIPAA. In addition to the information provided above, you should be aware that:

• We are required by law to maintain the privacy and security of your protected health information.
• We will notify you promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this Privacy Policy and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information, visit: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html

15. Acknowledgment