Privacy Policy

This document describes how RxPulse collects, uses, discloses, and safeguards information from users of the RxPulse service (the “User” or “Users”). It refers to the same Service described in our Terms & Conditions.

Personal data means all information about an identified or identifiable person. Users’ personal data are processed on the basis of a contract concluded between the User and RxPulse.

User-provided information. When you use the Service, you may provide and we may collect personally identifiable information, including without limitation: your name, email address, phone number, date of birth, mailing address, username, password, gender, age, geographic area, preferences, payment information (such as card number, expiration date, billing address), and insurance information. We may also receive health information from you or on your behalf, such as records relating to your medical or health history, health status, laboratory results, diagnostic images, and other health-related information.

Voice and conversation data. When you interact with Allie, our AI companion, we may process your voice transcript and the resulting conversation history to provide personalized assistance, improve the Service, and surface clinically relevant patterns to your care team where authorized. Voice data is not used for advertising and is not sold.

Automatically collected information. We may collect information about your use of the Service, including your IP address, browser type, device identifiers, operating system, referring URL, pages visited, links clicked, and timestamps. We may use cookies and similar technologies to recognize you, store preferences, and improve the Service.

Third-party buttons and widgets. The Service may include third-party widgets that may allow third parties to collect information about you through their own browser cookies. Information collected by such third parties is subject to their own data policies.

Do Not Track signals. We do not track our users over time and across third-party websites to provide targeted advertising and we do not respond to DNT signals.

Information from other sources. We may obtain information from partners or Providers and combine it with the information we collect through the Service, in which case we treat the combined information as personal information in accordance with this Policy.

We use information we collect on the Service in a variety of ways, including:

• To operate, maintain, enhance, and provide all features of the Service;
• To provide the services and information you request, including the meal plan, care plan, and Allie;
• To respond to comments and questions and communicate with you about the Service;
• To verify your identity and detect, prevent, investigate, and respond to fraud or misuse;
• To process payment card transactions and otherwise provide support;
• To understand and analyze usage trends and preferences, improve the Service, and develop new products and features;
• To send you communications, including updates, promotions, and events relating to RxPulse, the Providers, and selected partners;
• To analyze de-identified information for research, public health, and other purposes not prohibited by applicable law.

We do not engage in cross-context behavioral advertising and we do not sell your personal information as that term is defined under applicable U.S. privacy laws.

Except as described in this Policy, we will not disclose your personal information to third parties without your consent. We may disclose information in the following circumstances:

• To Providers for treatment, payment processing, or operational purposes;
• To third-party service providers who perform website, hosting, payment, analytics, or other services on our behalf (for example, Stripe and Google Analytics);
• To other companies and brands under common ownership with RxPulse, which will use your personal information in the same way as we can under this Policy;
• To comply with applicable law, court order, or other legal process;
• To take precautions against liability, protect against fraudulent or unlawful activity, defend against third-party claims, or protect property and legal rights;
• In connection with a merger, acquisition, financing, sale of assets, insolvency, bankruptcy, or receivership; and
• In de-identified or aggregated form for any business or other purpose not prohibited by law.

You may decline to share certain personal information with us, in which case some features of the Service may not be available. You may update, correct, or delete your profile information at any time through your account preferences. To request access, correction, deletion, or to make any other privacy-related request, email privacy@rxpulse.care.

You may unsubscribe from promotional communications at any time by following the instructions in any email we send. Even after you opt out of promotional messages, you will continue to receive administrative messages necessary to provide the Service. It may take up to ten (10) business days for opt-out requests to take full effect.

Social media widgets.The Service may include features such as “like” or “share” buttons. These social media companies may recognize you and collect information about your visit, governed by their own privacy policies.

Cookies. Most browsers allow you to control cookies. Blocking or deleting cookies may impact your experience using the Service.

Interest-based advertising. We do not engage in cross-context behavioral advertising. To opt out of interest-based advertising more broadly, visit the Network Advertising Initiative (networkadvertising.org) or Digital Advertising Alliance (aboutads.info).

Analytics. We use Google Analytics (or similar tools) to understand how users engage with the Service and to compile aggregate reports.

The Service may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites is subject to those operators’ policies, even when accessed through the Service. We encourage you to learn about third-party privacy practices before providing them with information.

The Service is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 without parental consent. If you are under 13, please do not use the Service. If you are a parent or guardian and discover that your child has used or accessed the Service, contact us at privacy@rxpulse.care and we will take appropriate steps to delete the information.

We use physical, technical, and administrative measures to protect the integrity and security of the personal information we collect and maintain. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We cannot guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our measures.

Although we may allow you to adjust your privacy settings to limit access to certain personal information, no security measures are perfect. We are not responsible for circumvention of any privacy settings or security measures. We cannot control the actions of other users with whom you choose to share your information.

The Service may only be used within certain jurisdictions in the United States as set forth in the Terms. This Policy and our collection, use, and disclosure of your information are governed by U.S. law. Using the Service from outside the United States is prohibited under our Terms and may subject you to termination. If you choose to access the Service from a region with data-protection laws that differ from U.S. law, you are transferring your personal information to the United States for storage and processing.

Please revisit this page periodically to stay aware of any changes to this Policy. If we modify it, we will update the date of the latest revision below. If the modifications materially alter your rights, we will make reasonable efforts to notify you (for example, via email or an in-app notice). Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version.

Please contact us with any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices by email at privacy@rxpulse.care.

By using the Service, you also acknowledge receipt of the Notice of Privacy Practices of the healthcare provider that you engage through the Service.

Providers accessible through the Service are employed by, or contract independently with, a professional corporation or other professional entity (the “Provider Group”), which is affiliated with RxPulse. We may use your information to send you communications on behalf of the Providers and to facilitate the provision of healthcare services.

Research. We may invite you to participate in IRB-approved research studies. Participation is voluntary and requires a separate, IRB-approved consent form that we will provide to you. Without your express consent to participate, we will not use your information for IRB-approved studies. We may, however, use information for other research purposes as described in this Policy.

Program Lead Portal.Information about your progress is shared with your support system, including your nutrition coach (the “Program Lead”) through the portion of the Service available to Program Leads. The Program Lead has access to program data to provide personalized coaching.

Safety alerts. If a User discloses, or a Program Lead observes, activities that present a concern for the safety or well-being of the User — such as hypertension, sharp blood-glucose changes, rapid weight loss or gain, mental health issues, or signs of abuse — RxPulse may alert the appropriate healthcare professional and disclose relevant personal information as we, in our sole discretion, deem necessary or appropriate.

Health-plan data. A health plan, or any agent, contractor, or vendor of your health plan, may electronically share information with us about your care (visits, conditions, recommendations) so that we can give you the best possible care. By agreeing to this Policy, you allow your health plan to share your personal health information with RxPulse, except where prohibited by law (for example, certain information relating to alcohol or substance abuse treatment).

Protected Health Information & HIPAA.Some of the information you submit, or that is created through your use of the Service, may constitute “protected health information” (“PHI”) as defined by HIPAA. PHI does not include information that has been de-identified in accordance with HIPAA. Even though RxPulse is not itself a “covered entity” as defined by HIPAA, the Provider and/or Provider Group may be a covered entity, and RxPulse may be subject to HIPAA requirements as a Business Associate. Provider Group has adopted a Notice of Privacy Practices describing how PHI is used and disclosed.

RxPulse has implemented measures designed to secure Users’ personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. RxPulse uses encryption technology for information sent and received over the Internet. The User is responsible for keeping the password to the Service confidential and not sharing it with anyone.

RxPulse reserves the right to unilaterally change and supplement this Policy. Changes become effective upon publication on the Service.

If any provision of this Privacy Policy becomes invalid, such invalidity will not affect the validity of the other provisions. RxPulse will replace any invalid provision with a new one consistent with the spirit of the rest of the Policy.

Effective Date: April 27, 2026.