Last update September 2, 2023

Slim MD Privacy Policy

Dripgym Mobile Parent LLC and its affiliates (“Slim-MD” “we,” or “us“) owns and operates this website and mobile app located at https://slim-md.com/ (collectively, the ” Platform“). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content (“Content“), any products or services provided through the Platform or otherwise by Slim-MD, and any affiliated website, software or application owned or operated by Slim-MD (collectively, including the Platform and the Content, the “Service“) are subject to this Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Slim-MD Terms of Service (“Terms of Service“).

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy (the “Privacy Policy“) to tell you how Slim-MD collects, uses and discloses information in order to provide you with the Service.
As with our Terms of Service, by creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are automatically accepting and acknowledging the most recent version of this Privacy Policy. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the “Last updated” date of the Privacy Policy.

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such individual to act on such individual’s behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such individual to act on such individual’s behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

Limitations on Use by Minors

Our Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. Individuals who are between the ages of thirteen (13) and eighteen (18) (or such older age of majority) may use the Service only if a parent or legal guardian provides consent to such use in accordance with the requirements set forth in our Terms of Service and the Service. The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

If you believe we might have any information directly from a child under 13, please contact us via email, or contact us form on our website.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Slim-MD to maintain the content or information; when Slim-MD maintains the content or information on behalf of your Providers (as defined in our Terms of Service) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Slim-MD anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Slim-MD’ voluntary practices concerning the collection of personal information through the Service from certain minors and is not intended to be an admission that Slim-MD is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

Protected Health Information

When you set up an account with Slim-MD, you are creating a direct customer relationship with Slim-MD that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide information to Slim-MD, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, that we do not consider to be “protected health information” or “medical information”.

However, in using certain components of the Service, you may also provide certain health or medical information that may be protected under applicable laws. Slim-MD is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, ” HIPAA“). One or more of the Labs, Pharmacies or Medical Groups (as defined in our Terms of Service) may or may not be a “covered entity” or “business associate” under HIPAA, and Slim-MD may in some cases be a “business associate” of a Pharmacy or Medical Group. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Slim-MD, the Medical Groups, the Providers, the Labs, or the Pharmacies. To the extent Slim-MD is deemed a “business associate” however, and solely in its role as a business associate, Slim-MD, may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to Slim-MD, the Medical Group or the Providers (” PHI“). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information“), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.

The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes how they use and disclose Protected Information. By accessing or using any part of the Service, you are acknowledging receipt of the Notice of Privacy Practices from your Medical Group and Provider(s). By accessing or using any part of the Service, you are agreeing that even if HIPAA does apply to Slim-MD, the Medical Groups, the Providers, the Labs or the Pharmacies, any information that you submit to Slim-MD that is not intended and used solely for the provision of diagnosis and treatment by the Medical Group and Providers, laboratory services by the Labs or prescription fulfillment by the Pharmacies, is not considered Protected Information, and will only be subject to our Privacy Policy and any applicable state laws that govern the privacy and security of such information. For purposes of clarity, information you provide to Slim-MD in order to register and set up an account on the Platform, including name, username, email address, shipping address and phone number, are not considered Protected Information.

Collection of Information

We collect any information you provide when you use the Service, including, but not limited to:

Personally identifying information such as your name and contact data such as your e-mail address, phone number, and billing and physical addresses
Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram)
Usage activity concerning your interactions with the Service and/or third-party websites, networks or applications accessed through the Service (e.g., viewing habits, viewing preferences, viewing history, number of clicks on a page or feature, amount of time spent on a page or feature, identify of third-party websites, networks, etc.)
Your login and password and other account (“Account“) registration details
Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services.
Records and copies of your correspondence (including email addresses), if you contact us;
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Demographic data (such as your gender, date of birth and zip code)
Computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes)
Billing, payment and shipping information
Electronic signature
Any other information you provide when you contact or communicate with us

If you use your mobile device to visit, access or use the Service, then additional categories of information that we collect may include

Your name associated with your mobile device
Your telephone number associated with your mobile device
Your mobile device ID information
Your geolocation

We also collect certain medical information on behalf of the Medical Groups and your Providers, which may include, but is not limited to:

Health and medical data you submit for diagnosis or treatment purposes, including information in any questionnaires or surveys you complete for these purposes
Communications with Providers
Date of visit
Images or videos you share for diagnosis or treatment purposes

We may also receive information about you from our partners. For example, as part of our identity verification process, our vendor may send us information they have independently collected, such as your name, age, and estimated location. Our marketing partners may also send us information about you, even if you have not visited or registered on our site.

Slim-MD does not collect or create biometric information about you. To use some of our services, however, we may be required to verify your identity. If you are asked to submit proof of identity (such as a driver’s license or passport) we may share that and the selfie you shared with us with our identity verification partner, who may create biometric information about your face in order to verify that your selfie matches your proof of identity. Biometric information is not shared with Slim-MD and is deleted by our identity verification partner after completing the identity verification. Slim-MD may receive information extracted from your photos, such as information from your driver’s license and the confidence that there is a “match” between your two photos. We use this information to help verify your identity.

How Information Is Collected

In connection with providing the Service, we and our affiliates and service providers may use your information, subject to the limitations addressed in the Protected Health Information Section above, for a number of purposes, including, but not limited to:

Administering your account;
Verifying your identity;
Processing your payments;
Confirming your location;
Fulfilling your requests;
Facilitating your movement through the Service;
Facilitating your use of the Service and/or products or services offered through the Service;
Communicating with you by letter, email, text, telephone or other forms of communication, including on behalf of your Provider(s) to facilitate medical services;
Providing you with information about Slim-MD, the Labs, the
Pharmacies, the Medical Groups, the Providers and/or their businesses, products and services by letter, email, text, telephone or other forms of communication;
Identifying or creating new products, services, marketing and/or promotions for Slim-MD or the Service;
Promoting and marketing Slim-MD, the Service, and the products and/or services offered via the Service;
Improving user experiences with the Service;
Providing you with customer support;
Providing you with information about third-party businesses, products and services by letter, email, text, telephone or other forms of communication;
Developing, testing or improving the Service and content, features and/or products or services offered via the Service;
Conducting research and measurement activities for purposes of research and development, advertising claim substantiation, market research, and other activities related to Slim-MD, the
Service or products and services offered via the Service;
Analyzing traffic to and through Service;
Analyzing user behavior and activity on or through the Service;
Monitoring the activities of you and others on or through the Service;
Placing and tracking orders for products or services on your behalf;
Protecting or enforcing Slim-MD’ rights and properties;
When required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process); or
Slim-MD believes in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of Slim-MD, a user of the Service, which may include you, or anyone else who may be harmed by such activities or to further Slim-MD’ legitimate business interests).
Protecting or enforcing the rights and properties of others (which may include you);

We may de-identify your information and use, create and sell such de-identified information, or any business or other purpose not prohibited by applicable law.

Disclosure of Information

Subject to the limitations described in the Protected Health Information section above, we may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information:

To the Labs, Pharmacies, Medical Group or its Providers to enable them to provide services to you via the Service and to collect payment on their behalf;
To our third-party and service providers (collectively “vendors”) that provide services to enable us to provide the Service, such as the hosting of the Service, data analysis, IT services and infrastructure, customer service, e-mail delivery, and other similar services;
To our subsidiaries and affiliates;
To our vendors that provide services to enable us to run our business and administrative operations, such as legal and financial advisory services, auditing services, analytics and similar services;
To our vendors that provide services to enable us to promote and advertise the Service and the products and/or services offered via the Service, such as ad platforms or ad-retargeting services, as well as comply with contact removal requests or requirements, such as mailing list removal services, do not call registries, and similar services;
To our contractors, service providers, and other third parties we use to support our business. These entities provide IT and infrastructure support services, payment processing services and marketing software. Our payment processors’ privacy policies may be found at http://stripe.com/us/privacy;
To vendors as we believe necessary or appropriate to comply with applicable laws; and
To a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Slim-MD’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal
Data held by Slim-MD about our Website’s users is among the assets transferred;
To fulfill the purpose for which you provide it;
For any other purpose disclosed by us when you provide the information; and
With your consent;
To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Slim-MD, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may de-identify your information and disclose such de-identified information for any purpose not prohibited by applicable law.

Data Retention

Slim-MD may retain your information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Service or Slim-MD. Slim-MD may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by Slim-MD or as required by law.

Similarly, the Medical Groups and Providers may retain your information for as long as they believe necessary; as long as necessary to comply with their respective legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Medical Groups and Providers. The Medical Groups and Providers may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by the Medical Groups or Providers or as required by law.

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website.

Transactions

In connection with any transaction that you conduct through the Service (e.g., the purchase or sale of any products or services on or through the Service), you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting such information, you grant Slim-MD without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to third parties (e.g., payment processing companies, buyers on the Service, sellers on the Service) for the purpose of facilitating the transaction.

All credit card, debit card and other monetary transactions on or through the Service occur through an online payment processing application(s) accessible through the Service. This online payment processing application(s) is provided by Slim-MD’ third-party online payment processing vendor, Stripe (“Stripe“). Additional information about Stripe, its privacy policy and its information security measures (collectively, the ” Stripe Policies“) should be available on the Stripe website located at https://stripe.com/us/privacy or by contacting Stipe directly. Reference is made to the Stripe Policies for informational purposes only and are in no way incorporated into or made a part of this Privacy Policy. Slim-MD’ relationship with Stripe, if any, is merely contractual in nature, as Stripe nothing more than a third-party vendor to Slim-MD, and is in no way subject to Slim-MD’ direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers or the like.

Jurisdictional Issues

The law in some jurisdictions may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state that is attached to this Privacy Notice.

Your California Privacy Rights

If you are a resident of California, you have the additional rights described in the California Privacy Addendum.

All credit card, debit card and other monetary transactions on or through the Service occur through an online payment processing application(s) accessible through the Service. This online payment processing application(s) is provided by Slim-MD’ third-party online payment processing vendor, Stripe (“Stripe“). Additional information about Stripe, its privacy policy and its information security measures (collectively, the ” Stripe Policies“) should be available on the Stripe website located at https://stripe.com/us/privacy or by contacting Stipe directly. Reference is made to the Stripe Policies for informational purposes only and are in no way incorporated into or made a part of this Privacy Policy. Slim-MD’ relationship with Stripe, if any, is merely contractual in nature, as Stripe nothing more than a third-party vendor to Slim-MD, and is in no way subject to Slim-MD’ direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers or the like.

Third Parties

This Privacy Policy does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third parties, including, without limitation, the Medical Group or its Providers, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Service may contain a link. These third parties may at times gather information from or about you. We do not control and are not responsible for the privacy practices of these third parties. We encourage you to review the Medical Group’s Notice of Privacy Practices and the privacy policies of each website and application you visit and use.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory authority about our processing of your Personal Data.

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

Access and Update. You can review and change your Personal Data by logging into the Website and visiting your “Account” page. You may also notify us through the Contact Information below or through our Website’s Contact Us form of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
You have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot delete your Personal Data except by also deleting your user account, and we will only delete your account when you have requested that we do so. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any of the methods listed under Contact Information below and through our Website’s Contact Us form. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.
You have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Changes to Our Privacy Notice

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Website’s home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

Contact Information

If you wish to contact us, you may contact both us through the the Contact Us form on our Website.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us through the Contact Us page on our Website.

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