CONSUMERHEALTH DATA PRIVACY POLICY
Last Updated: June 18, 2026
Pepcision, LLC, a Florida limited liability company ("Pepcision," "we," "us," or "our") provides this Consumer Health Data Privacy Policy ("Policy") to describe how we collect, use, disclose, and protect Consumer Health Data in connection with the Platform and Service. This Policy supplements our general Privacy Policy and applies to the extent required by applicable state consumer health data laws.
This Policy does not replace or supersede:
- The Notice of Privacy Practices issued by our independent telehealth partner Arora and its licensed healthcare providers ("Providers"), or
- Any HIPAA obligations that apply to Arora, the Providers, or the dispensing pharmacy.
For information about how your medical records, treatment information, and Protected Health Information (PHI) are handled in the context of clinical care, please refer to Arora's Notice of Privacy Practices, which is provided during the telehealth process or available upon request from Arora.
What is Consumer Health Data?
"Consumer Health Data" generally refers to personal information that identifies or is reasonably linkable to you and that relates to your physical or mental health status, medical history, symptoms, diagnoses, treatments, medications, or health-related decisions, as defined under applicable state laws (such as Washington's My Health My Data Act and similar laws in other states).
This includes, for example:
- Health-related information you provide when requesting or participating in telehealth consultations through the Platform.
- Wellness goals, symptoms, medical history, or product preferences you voluntarily submit in connection with wellness or peptide products.
- Information about prescriptions or health-related products you order through the Platform.
- Certain inferences we may draw about your health from your activity on the Platform.
Note: Clinical records created or maintained by Arora and the Providers in connection with medical treatment are primarily governed by Arora's Notice of Privacy Practices and applicable healthcare privacy laws (including HIPAA where it applies). Pepcision's collection and use of Consumer Health Data is generally limited to platform facilitation, coordination, and non-clinical wellness purposes.
Categories of Consumer Health Data We Collect
We may collect the following categories of Consumer Health Data:
- Information you provide directly through questionnaires, forms, account profiles, or communications related to wellness needs or telehealth requests.
- Health-related purchase and order history (e.g., specific peptide or wellness products ordered).
- Information received from Arora necessary to coordinate telehealth services and prescription fulfillment (subject to our agreements with Arora and applicable law).
- Usage data and inferences that may relate to health or wellness interests (e.g., pages viewed, products considered).
We do not collect genetic information, biometric data for identification purposes, or other highly sensitive categories of health data unless you voluntarily provide it in connection with the Service.
How We Collect Consumer Health Data
We collect Consumer Health Data:
- Directly from you when you use the Platform, complete forms, request consultations, or make purchases.
- From Arora and its Providers, with appropriate safeguards and agreements in place, to facilitate the Service.
- Automatically through your interactions with the Platform (e.g., through cookies and analytics tools that may infer wellness interests).
How We Use Consumer Health Data
We use Consumer Health Data for purposes such as:
- Facilitating your access to telehealth consultations with Arora and prescription fulfillment through the Pharmacy.
- Processing and fulfilling orders for wellness and health-related products.
- Personalizing product recommendations and wellness content based on your stated goals and activity.
- Providing customer support and responding to your inquiries.
- Improving and developing our Platform, products, and services.
- Detecting and preventing fraud or misuse of the Service.
- Complying with legal and regulatory obligations.
- Other purposes disclosed to you at the time of collection or with your consent.
We do not use Consumer Health Data to make decisions about your eligibility for credit, employment, or insurance, or for any discriminatory purpose.
How We Share and Disclose Consumer Health Data
We share Consumer Health Data only as necessary and in the following circumstances:
- Arora and Providers: To enable telehealth consultations, medical evaluations, and the issuance of prescriptions. This is the primary way health-related information is used for clinical purposes.
- Pharmacy Partners: Limited information necessary for the Pharmacy to fill and ship prescriptions in accordance with the Provider's orders and applicable pharmacy law.
- Service Providers: With vendors and contractors that help us operate the Platform (e.g., hosting, analytics, customer support, or marketing services). These parties are subject to contractual confidentiality and data protection obligations.
- Legal Requirements: When required by law, court order, or government request, or to protect the rights, safety, or property of Pepcision, our users, or others.
- Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to appropriate protections for your information.
- With Your Consent: When you direct us to share your information or otherwise provide consent.
We do not sell Consumer Health Data for monetary or other valuable consideration. We also do not share Consumer Health Data for cross-context behavioral advertising or targeted advertising in a manner that would constitute a "sale" or "sharing" under applicable state consumer health data laws, except where you have been provided clear notice and an opportunity to opt out (if required).
Your Rights Regarding Consumer Health Data
Subject to applicable state law and certain exceptions, you may have the following rights with respect to your Consumer Health Data:
- Right to Know / Access: Request confirmation of whether we are processing your Consumer Health Data and obtain a copy of the data we hold.
- Right to Correction: Request correction of inaccurate Consumer Health Data.
- Right to Deletion: Request deletion of your Consumer Health Data (subject to legal retention requirements and exceptions, such as data needed to complete a transaction or comply with law).
- Right to Opt Out: Opt out of the processing or sharing of your Consumer Health Data for certain purposes, including targeted advertising or sale (where applicable).
- Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time.
- Right to Non-Discrimination: Exercise your rights without being discriminated against.
To exercise these rights, please submit a request using the contact information below or through any designated privacy request form on the Platform. We will verify your identity and respond within the timeframes required by applicable law. If you are submitting a request on behalf of another individual, we may require authorization documentation.
Note: For clinical health records and treatment-related information held by Arora and the Providers, you should direct your requests to Arora in accordance with their Notice of Privacy Practices.
Data Security
We maintain reasonable technical, administrative, and physical safeguards designed to protect Consumer Health Data against unauthorized access, use, or disclosure. These safeguards are consistent with or exceed the protections described in our general Privacy Policy, with heightened attention given to the sensitivity of health-related information.
Data Retention
We retain Consumer Health Data only for as long as necessary to fulfill the purposes described in this Policy, to provide the Service, to comply with legal obligations (including healthcare record retention requirements where applicable), or to resolve disputes. When retention is no longer necessary, we securely delete or de-identify the data.
Changes to This Policy
We may update this Consumer Health Data Privacy Policy from time to time. We will post the updated version on the Platform with a revised "Last Updated" date. Material changes will be communicated as appropriate. Your continued use of the Platform after any update constitutes acceptance of the revised Policy.
Contact Us
If you have questions about this Consumer Health Data Privacy Policy, wish to exercise your rights, or have concerns about how we handle Consumer Health Data, please contact us at:
Email: support@margomd.com
For matters related to clinical care, medical records, or treatment by Arora and the Providers, please contact Arora directly using the contact information provided in their Notice of Privacy Practices or during your consultation.
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