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Política de privacidad

Última revisión: julio de 2025

Version 1.1

1. Propósito

NourishedRx values and is committed to protecting our members’ data and privacy. The terms “NourishedRx,” “we,” and “us” include Project Well, Inc., DBA NourishedRx, and our affiliates and subsidiaries. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, and how we intend to use and share that information.

2. Alcance

This Privacy Policy applies to Personal Information that is collected and processed by NourishedRx in the course of our business, including on NourishedRx websites (each a “Site”), mobile applications, artificial intelligence-enabled chatbot or similar automated tool (the “AI Chatbot”), messaging tools, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of NourishedRx, the “Services”).

The AI Chatbot may allow you to interact with automated technology to receive general information, navigation support, reminders, educational content, program-related assistance, and other features made available by NourishedRx from time to time. References in this Privacy Policy to the Site or Services include the AI Chatbot and your interactions with it, unless the context requires otherwise.

This Policy applies to all of NourishedRx’s operating divisions, subsidiaries, affiliates, and any additional subsidiary or affiliate of NourishedRx that we may subsequently form.

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services, including the AI Chatbot, after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services. If there are any material changes to this Privacy Policy, NourishedRx will notify you by email, by an alert through the Services, or as otherwise required by applicable law.

Definitions

“AGENT” means any contractor, service provider, or agent of NourishedRx.

“AI CHATBOT” means an artificial intelligence-enabled chatbot, automated assistant, or similar automated tool made available by or on behalf of NourishedRx through the Services.

“PERSONAL INFORMATION” is any information relating to or that can reasonably be linked to an identified or identifiable natural person (“Individual”).

“PROCESSES” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“SENSITIVE DATA” or “SENSITIVE PERSONAL INFORMATION” is a subset of Personal Information which may consist of the following information, as defined under applicable data protection laws: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (7) PHI/PII; (8) sexual orientation or information about the Individual’s sex life; or (9) information relating to the commission of a criminal offense.

“THIRD-PARTY” is any company, natural or legal person, public authority, agency, or body other than the Individual, NourishedRx or NourishedRx’s Agents.

3. Transparencia/Aviso

Types of Personal Information We Collect And How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with NourishedRx and the requirements of applicable law. Some of the ways that NourishedRx may collect Personal Information include:

You may provide Personal Information directly to NourishedRx through interacting with the Services, including the AI Chatbot, participating in surveys, requesting Services or information, or otherwise communicating with us.

As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

Below are the ways we collect Personal Information and how we use it.

3.1 Tipos de información personal que recopilamos

NourishedRx collects Personal Information regarding its current, prospective, and former clients, users, visitors, guests (collectively “Individuals”).

Information You Provide Directly to Us

When you use the Services or engage in certain activities, such as registering for an account with NourishedRx, responding to surveys, requesting Services or information, using or interacting with the AI Chatbot, or contacting us directly, we may ask you to provide some or all of the following types of information:

Communications with Us

We may collect Personal Information from you such as name, email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, interact with the AI Chatbot, or otherwise communicate with us. This may also include any information you choose to provide in the message box on the “Contact Us” page of our Site or through any chatbot, messaging, or communication feature.

Registering for an Account

This is the Personal Information that is provided by you or collected by us, including through your health plan, on your own, or through other authorized health partners, to enable you to login and access your account and/or our Services. This may include your name, address, date of birth, email address, and phone number. You also have the option to provide us with some additional Personal Information in order to make your account more personalized. Personal information collected may include but is not limited to medical history (including past and current diagnoses), medication and supplement use, known allergies and sensitivities, surgical history and past procedures, family health history, laboratory test results (e.g., blood work, GI tests), medical imaging (e.g., X-rays, scans), health behaviors (e.g., diet, physical activity, sleep patterns), reproductive or menstrual health, when applicable, social determinants of health (e.g., housing, food access, income status), insurance details and healthcare provider information, notes from nutrition consultations and related assessments, and communication logs with clinical staff.

AI Chatbot Interactions

When you use or interact with the AI Chatbot, we may collect and Process information associated with those interactions, including your prompts, questions, messages, instructions, uploaded or submitted content, AI Chatbot responses or outputs, conversation history, feedback, timestamps, technical information, metadata, and other information associated with your use of the AI Chatbot. This information may include Personal Information, health-related information, eligibility information, preferences, food or nutrition-related information, delivery or program information, and any other information you choose to provide through the AI Chatbot.

You should not submit information through the AI Chatbot that you are not authorized to provide. If you provide information about another person, you represent that you have the legal authority and any required consent to provide such information and to permit NourishedRx to use it in accordance with this Privacy Policy and our Terms and Conditions.

You should not use the AI Chatbot for medical emergencies or urgent medical needs. If you are experiencing a medical emergency, believe you may have an emergency medical condition, or need urgent medical attention, call 911 or seek emergency medical care immediately.

Surveys

If you use our Services, from time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include self-reported health information, and which may include information about your reproductive or mental health. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to provide services to you, improve our Sites and Services and in any manner consistent with the policies provided herein.

Automatic Data Collection

We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.

When you interact with the AI Chatbot, we may also automatically collect technical and usage information related to those interactions, such as session identifiers, conversation identifiers, timestamps, feature usage, device and browser information, performance data, error logs, and information used to operate, secure, support, analyze, and improve the AI Chatbot and Services.

Information Submitted Via Services

You agree that NourishedRx may use the content of communications submitted by you via the Services, including through the AI Chatbot, and any ideas, concepts, feedback, prompts, questions, preferences, and other information disclosed therein, for purposes consistent with this Privacy Policy, including operating, providing, maintaining, securing, supporting, analyzing, and improving the Services, Site, AI Chatbot, and related offerings. To the extent any such content includes Personal Information, NourishedRx will Process that Personal Information in accordance with this Privacy Policy.

Information from Other Sources

We may receive information about you from other sources, including Third-Party services and organizations such as your health plan or other authorized associates. We may use this information to provide the Services. Information provided from your health plan or authorized associates may include Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). You shall not submit PHI through the Services, including the AI Chatbot, unless expressly directed by NourishedRx. This information may also allow us to verify information that you have provided to NourishedRx and to enhance our ability to provide you with information about our business and Services.

3.2 Cómo usa NourishedRx su información

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

To Provide Services or Information Requested

NourishedRx may use information about you to fulfill requests for Services or information, including information about potential or future Services, including to:

Administrative Purposes

NourishedRx may use Personal Information about you for its administrative purposes, including to:

Research and Development

NourishedRx may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services, including improvements to the AI Chatbot and related features. From time to time, NourishedRx may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

Communication

Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, text messages, AI Chatbot messages, in-app messages, or phone calls from us with information on NourishedRx’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. Individuals may decline these communications by following the instructions in Section 5 below.

Services via Mobile Devices

From time to time, NourishedRx may provide Services that are specifically designed to be compatible and used on mobile devices. NourishedRx will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of NourishedRx’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts, including information about use of AI Chatbot features within mobile Services.

Anonymous and Aggregated Information Use

NourishedRx may use Personal Information and other information about you, including information associated with AI Chatbot interactions, to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, de-identified chatbot usage information, information about the computer or device from which you access NourishedRx’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and NourishedRx may use such information in a number of ways, including research, internal analysis, analytics, product improvement, AI Chatbot improvement, and any other legally permissible purposes. We may share this information within NourishedRx and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

3.3 Cookies, etiquetas de píxeles/balizas web, información analítica y publicidad basada en intereses ‍

We, as well as Third Parties that provide content, advertising, analytics, AI Chatbot functionality, communications functionality, or other functionality on our Services, may use cookies, pixel tags, web beacons, and other tracking technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, AI Chatbot, and tools, and to recognize you across devices.

Cookies

Cookies are small text files placed in visitors’ computer or device browsers to store their preferences. You may be able to block and delete cookies by changing the settings on your browser or device. However, if you do that, the website may not work properly and certain functionalities will be unavailable to you.

Pixel Tags/Web Beacons

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary

We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Sites, Services, applications, AI Chatbot, and tools. This includes technologies that allow you access to our Sites, Services, applications, AI Chatbot, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, chatbot conversations, or similar functions.

Performance Related

We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites and Services, applications, AI Chatbot, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging or AI Chatbot, determine whether you have viewed an item or link, or to improve our Site content, Services, applications, AI Chatbot, or tools.

Functionality Related

We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, AI Chatbot, or tools. This may include identifying you when you sign into our Sites, maintaining chatbot session continuity, or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites or through the Services.

Advertising or Targeting Related

We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our Sites, Services, applications, AI Chatbot, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 Sitios web de terceros

Our website or applications may contain links to other websites and other websites may reference or link to our website or other Services. These other domains and websites are not controlled by us, and NourishedRx does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the security or privacy practices or content of such other websites or applications. Visiting and utilizing these other websites or applications is at your own risk.

4. Cómo NourishedRx comparte su información

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent

When required, we will obtain your consent to process your personal information for specific purposes. We may also receive your consent through your health plan/authorized associate, or authorized third party acting on your behalf. You may withdraw consent at any time, subject to applicable legal or contractual limitations. In some instances, we may process your personal information without consent where permitted or required by law.

Legitimate Interests

We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract

Where we have entered into a contract with you/your health plan/authorized associate, we may process your personal information to fulfill the terms of our contract.

Legal Obligations

We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests

We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

We may share your information as described in this Privacy Policy with our Third-Party service providers; to provide you with our services; to comply with legal obligations; to protect and defend our rights and property; with your permission; and as otherwise set forth below.

We Use Vendors and Service Providers

We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for:

Business Partners

We may share Personal Information with our business partners, including food fulfillment vendors, food delivery partners, technology partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a Service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name may appear, along with us, or independently on their own.

AI Technology Providers and Chatbot Support

We may share information associated with your use of the AI Chatbot, including prompts, questions, messages, conversation history, metadata, and related Personal Information, with Agents, vendors, service providers, and technology providers that help us operate, host, maintain, secure, support, monitor, analyze, or improve the AI Chatbot and Services. These providers may Process information on our behalf and are expected to use the information only as permitted by our agreements with them and applicable law.

Health Plans

We may share Personal Information with your health plan or authorized health associates as part of the Services that you have received.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures)

We may access, preserve, and disclose your Personal Information, AI Chatbot interactions, other account information, and content if we believe doing so is required or appropriate to:

In addition, NourishedRx may share your Personal Information with Third Parties where required by applicable law, where it is necessary in connection with our Services, or where we have another legitimate interest in doing so.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be shared or transferred as part of such a transaction.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. However, mobile information may be shared with trusted partners for legitimate business purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. Exclusión voluntaria de las comunicaciones

5.1 Generalidades

You have the right to object to and opt out of certain uses and disclosures of your Personal Information as set forth below.

5.2 Comunicaciones telefónicas y por correo electrónico

By providing your phone number and/or email address you have given consent to receive communications from NourishedRx including phone calls, text messages (SMS), and emails. If you would like to opt out of marketing-related email or text message communications from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future marketing emails, by replying “STOP” if you receive NourishedRx SMS communications, or by contacting us as set forth in this Privacy Policy. We will process your request in accordance with applicable communication regulations. You will continue to receive transaction-related emails and SMS communications regarding Services you have requested. We may also send you certain transactional communications regarding NourishedRx and our Services (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “Do Not Contact” lists as mandated by law. We process requests to be added to our Do Not Contact lists within 10 days of receipt, or within any shorter time frame as required by applicable regulations.

5.3 AI Chatbot Communications

Depending on the features made available by NourishedRx, the AI Chatbot may provide transactional, operational, program-related, or informational messages, reminders, responses, or other communications through the Services. If you do not wish to use the AI Chatbot, you should stop interacting with the AI Chatbot. Your ability to opt out of certain AI Chatbot-related communications or features may affect the availability, functionality, personalization, or fulfillment of certain Services.

5.4 Cookies y publicidad basada en intereses

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that users do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.5 Cookies and Internet-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences, if permitted by your device or browser. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device.

6. Sus derechos

You can view, update, and delete information about your account and your interactions through your account or otherwise by sending an e-mail to compliance@nourishedrx.com. You have choices about the collection and use of your personal information. You consent by default to our Privacy practices by using our services, including the AI Chatbot, but you have the option to not do so by emailing us. You can choose not to provide certain information or disagree with our privacy practices, but then you might not be able to take advantage of our services to the fullest. You have the right to review, change, or terminate your account at any time.

Subject to applicable law, your rights may apply to Personal Information associated with AI Chatbot interactions, including prompts, messages, responses, conversation history, metadata, and related information that can reasonably be linked to you.

Rights regarding Protected Health Information (PHI)

Right to Amend PHI

If a user feels that their PHI is incomplete or inaccurate, then they have the right to request that NourishedRx amend that error.

Right to Access PHI

Users have the right to access their PHI and request copies of their PHI. All requests for copies must be made to compliance@nourishedrx.com. We may charge a reasonable fee for the costs of copying and mailing users’ requested information, and we will inform each user of the cost prior to incurring any costs.

Right to Accounting of Disclosures

Users have the right to request an accounting of to whom NourishedRx has disclosed their PHI. This must be made to compliance@nourishedrx.com and must specify the time period within which the user wants an accounting. The time period may not be more than 6 years. Each user is entitled to one free accounting per 12-month period, and each additional request for an accounting within that time period shall bear a reasonable cost, and we will inform each user of the cost prior to incurring any costs.

Right to Request Restrictions on Use and Disclosure of PHI

Users have the right to restrict or limit how NourishedRx uses or discloses your PHI. A request must be made to compliance@nourishedrx.com, and must inform NourishedRx which information is to be limited, whether use or disclosure or both should be limited, and to whom the restrictions apply.

Right to Receive Confidential Communications

Users have the right to request that NourishedRx deliver communications in a certain way if NourishedRx’s normal communications channels could endanger the user. This request must be made to compliance@nourishedrx.com and must state whether all or part of the communication could endanger the user.

Right to a Paper Copy of this Policy

Users have the right to request a paper copy of this privacy policy at any time. We may charge a reasonable fee for the costs of copying and mailing users’ requested information, and we will inform each user of the cost prior to incurring any costs.

Right to Nominate a Representative

Users can designate someone to act on your behalf with respect to your PHI.

Right to Revoke Authorizations

Users can revoke authorizations for sharing your PHI.

If you would like to exercise any of these rights, please contact us at our email: compliance@nourishedrx.com.

7. Retención de datos

NourishedRx retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, comply with legal, accounting, and reporting obligations, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws and regulations. This may include Personal Information associated with AI Chatbot interactions, such as prompts, messages, responses, conversation history, metadata, technical logs, and related information. Additionally, we may continue to store your Personal Information in our standard backups in accordance with NourishedRx policies. Retention periods may vary depending on the type of data and applicable legal or contractual requirements.

8. Seguridad de su información

At NourishedRx, security is our highest priority. We design our systems with your security and privacy in mind. We maintain a variety of compliance programs that validate our security controls periodically. We protect the security of your information during transmission to or from our website, applications, products, AI Chatbot, or services by using encryption protocols. We maintain strict physical, electronic, and administrative safeguards in connection with the collection, storage, and disclosure of personal information whether the data is collected from you or other sources.

Our Company securely stores all your data electronically with measures to protect your Protected Health Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with HIPAA and other applicable laws and regulations. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process, including information associated with AI Chatbot interactions. We take the security of your personal information seriously and use various measures to protect it. However, no method of online transmission or storage is completely secure, so we cannot guarantee that unauthorized parties will never be able to access your information. While we do our best to keep your data safe, we highly recommend using our Website, Applications, AI Chatbot, and Services in a secure environment.

By using the Site or Services, including the AI Chatbot, or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site or Services.

9. Información confidencial

If you send or disclose any Sensitive Personal Information to us, including through the AI Chatbot, you consent to our processing and use of such Sensitive Personal Information in accordance with this Privacy Policy. If you do not consent to our processing and use of such Sensitive Personal Information, you must not submit such content to our Services.

You should not submit PHI, Sensitive Personal Information, information about another person, or other sensitive information through the AI Chatbot unless you are authorized to do so and, where applicable, expressly directed by NourishedRx.

10. AI Chatbot Notice

The AI Chatbot is an automated tool and may generate responses based on information available to it, information you provide, and automated processing. AI Chatbot responses may be incomplete, inaccurate, outdated, unavailable, delayed, or not tailored to your individual circumstances. The AI Chatbot does not replace human review, clinical judgment, or advice from a physician, registered dietitian, nutritionist, pharmacist, nurse, or other qualified healthcare provider.

Information submitted to or generated through the AI Chatbot may be monitored, captured, recorded, reviewed, retained, analyzed, and used in accordance with this Privacy Policy, including for operating, providing, maintaining, securing, supporting, personalizing, analyzing, and improving the Services and AI Chatbot; responding to your requests; coordinating Services; addressing safety, quality, security, fraud, abuse-prevention, legal, and compliance matters; and complying with applicable law.

Do not use the AI Chatbot for medical emergencies or urgent medical needs. If you are experiencing a medical emergency, believe you may have an emergency medical condition, or need urgent medical attention, call 911 or seek emergency medical care immediately.

10. Resarcimiento/cumplimiento y responsabilidad

This California Privacy Notice applies to California residents and supplements the information contained in the rest of this Privacy Policy. This section applies only to the extent NourishedRx is subject to the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its implementing regulations (collectively, the “CCPA”). Terms used in this section have the meanings given to them under the CCPA.

11.1 Categories of Personal Information We Collect

In the preceding 12 months, we may have collected the following categories of Personal Information, depending on your relationship with NourishedRx and how you use the Services, including the AI Chatbot:

11.2 Sensitive Personal Information

We may collect Sensitive Personal Information as described above and elsewhere in this Privacy Policy, including health-related information and information submitted through the AI Chatbot. We use and disclose Sensitive Personal Information for purposes permitted by the CCPA, including to provide requested Services, perform Services reasonably expected by an average consumer, ensure security and integrity, prevent fraud or illegal activity, maintain quality and safety, perform services on behalf of NourishedRx, comply with law, and otherwise as permitted by applicable law.

NourishedRx does not use or disclose Sensitive Personal Information for the purpose of inferring characteristics about a California consumer except as permitted by applicable law or as otherwise disclosed at or before collection. If NourishedRx uses or discloses Sensitive Personal Information in a manner that gives rise to a right to limit under the CCPA, NourishedRx will provide a method for California consumers to exercise that right.

11.3 Purposes for Collecting, Using, and Disclosing Personal Information

We collect, use, and disclose Personal Information for the business and commercial purposes described in this Privacy Policy, including to:

11.4 Sale or Sharing of Personal Information

NourishedRx does not sell Personal Information for money. NourishedRx also does not knowingly sell or share Personal Information of consumers under 16 years of age.

The CCPA defines “sale” and “sharing” broadly. If NourishedRx engages in activities that constitute a “sale” or “sharing” of Personal Information under the CCPA, including sharing for cross-context behavioral advertising, NourishedRx will provide California consumers with a method to opt out, such as a “Do Not Sell or Share My Personal Information” link or other legally recognized mechanism. If NourishedRx does not sell or share Personal Information within the meaning of the CCPA, NourishedRx will disclose that fact in this Privacy Policy or at the point of collection as required by law.

11.5 Disclosure of Personal Information for Business Purposes

In the preceding 12 months, NourishedRx may have disclosed the categories of Personal Information listed in Section 11.1 for business purposes to the categories of third parties identified in Section 11.1, including service providers, contractors, technology providers, hosting providers, analytics providers, AI technology providers, messaging providers, food fulfillment and delivery partners, health plans or authorized associates, and legal or compliance recipients.

11.6 Retention

We retain Personal Information, including Personal Information associated with AI Chatbot interactions, for as long as reasonably necessary to fulfill the purposes for which it was collected, provide the Services, comply with legal, accounting, contractual, and reporting obligations, resolve disputes, establish legal defenses, maintain security, enforce agreements, and pursue legitimate business purposes. Retention periods may vary depending on the nature of the information, the Services provided, applicable law, contractual requirements, and operational needs.

11.7 California Consumer Rights

Subject to applicable law and verification, California consumers may have the following rights:

11.8 How to Exercise California Rights

To exercise your California privacy rights, you may contact us at compliance@nourishedrx.com. If NourishedRx is required by law to provide additional request methods, such as a toll-free number or webform, NourishedRx will make those methods available and identify them in this Privacy Policy or in a California-specific notice.

We may need to verify your identity before processing certain requests. Verification may require us to match information you provide with information we maintain about you. We will use Personal Information collected for verification only for verification and request-processing purposes, except as permitted by law. If you maintain an account with us, we may require you to submit or verify certain requests through your account.

We will respond to verifiable consumer requests within the time required by applicable law. If we need additional time, we will notify you as required by law. You generally may make a request to know/access no more than twice within a 12-month period.

11.9 Authorized Agents

You may authorize another person to submit a CCPA request on your behalf. We may require proof that you authorized the agent to act on your behalf and may also require you to verify your identity directly with us or confirm that you provided the authorized agent permission to submit the request, unless otherwise prohibited by law.

11.10 Opt-Out Preference Signals

If NourishedRx is required to honor opt-out preference signals under applicable law, we will process such signals in accordance with the CCPA and applicable regulations. Depending on the signal and our ability to associate it with you, an opt-out preference signal may apply to the browser, device, or consumer account through which the signal is sent.

11.11 Financial Incentives

NourishedRx does not currently provide financial incentives or price or service differences in exchange for the collection, retention, sale, or sharing of Personal Information within the meaning of the CCPA. If NourishedRx offers such a program in the future, we will provide any required notice and obtain any required consent.

11.12 HIPAA and Other Legal Exemptions

Certain health information may be subject to HIPAA or other healthcare privacy laws and may be exempt from some CCPA requirements. Other Personal Information that is not exempt may remain subject to the CCPA. NourishedRx will process requests involving health information in accordance with applicable law.

11. Política de información infantil

This section supplements the rest of this Privacy Policy and applies to residents of U.S. states with comprehensive consumer privacy laws, to the extent those laws apply to NourishedRx and to the Personal Information at issue. Depending on your state of residence and subject to applicable legal exceptions, you may have some or all of the rights described below.

For purposes of this section, “Personal Information” may also be referred to as “personal data” under certain state laws, and “Sensitive Personal Information” may also be referred to as “sensitive data.”

12.1 Categories of Personal Data We Process

We may process the categories of Personal Information described in this Privacy Policy, including identifiers, account information, contact information, program eligibility information, food and delivery-related information, health-related information, communications, AI Chatbot prompts, messages, responses, conversation history, metadata, technical and usage information, preferences, survey responses, inferences, and other information you provide or that we receive from authorized sources.

12.2 Purposes for Processing Personal Data

We process Personal Information for the purposes described in this Privacy Policy, including to:

12.3 Categories of Personal Data Shared with Third Parties

We may disclose or share the categories of Personal Information described in this Privacy Policy with the categories of recipients described in this Privacy Policy, including service providers, contractors, technology providers, hosting providers, analytics providers, AI technology providers, messaging providers, food fulfillment and delivery partners, health plans or authorized associates, business partners where applicable, and legal, regulatory, or compliance recipients.

12.4 Your State Privacy Rights

Depending on your state of residence and subject to applicable law, you may have the right to:

12.5 Sensitive Personal Information

We may process Sensitive Personal Information as described in this Privacy Policy, including health-related information and information submitted through the AI Chatbot. We process Sensitive Personal Information to provide requested Services, perform Services reasonably expected by users, ensure security and integrity, prevent fraud or illegal activity, maintain quality and safety, support and improve the Services and AI Chatbot, comply with law, and otherwise as permitted by applicable law.

Where applicable state law requires consent before processing Sensitive Personal Information, we will obtain consent or rely on another legally permitted basis before processing such information. You should not submit Sensitive Personal Information, PHI, information about another person, or other sensitive information through the AI Chatbot unless you are authorized to do so and, where applicable, expressly directed by NourishedRx.

12.6 Targeted Advertising, Sale, and Profiling

NourishedRx does not sell Personal Information for money. If NourishedRx processes Personal Information for targeted advertising, sells Personal Information as defined by applicable state law, or conducts profiling in furtherance of decisions that produce legal or similarly significant effects, NourishedRx will provide applicable opt-out rights and mechanisms as required by law.

The AI Chatbot is intended to support general information, navigation, reminders, educational content, program-related assistance, and related Services. NourishedRx does not intend for the AI Chatbot to replace human review, clinical judgment, or professional healthcare advice. If NourishedRx uses automated processing, profiling, or AI Chatbot interactions in a manner that produces legal or similarly significant effects, NourishedRx will provide any notices and rights required by applicable law.

12.7 How to Exercise State Privacy Rights

To exercise applicable state privacy rights, you may contact us at compliance@nourishedrx.com. If applicable law requires additional request methods, NourishedRx will make those methods available.

We may need to verify your identity before processing your request. Verification may require us to match information you provide with information we maintain about you. We will use information collected for verification only for verification and request-processing purposes, except as permitted by law.

12.8 Appeals

If we deny your privacy rights request and applicable law gives you a right to appeal, you may appeal our decision by contacting us at compliance@nourishedrx.com and stating that you are appealing a privacy rights decision. We will review and respond to your appeal within the time required by applicable law.

12.9 Authorized Agents

Where permitted by applicable law, you may authorize another person to submit a privacy rights request on your behalf. We may require proof that the agent is authorized to act on your behalf and may require you to verify your identity directly with us, unless prohibited by law.

12.10 State Law Variations

State privacy laws vary and may not apply to all Individuals, all entities, or all Personal Information. Certain information may be exempt from state privacy laws, including information subject to HIPAA or other healthcare privacy laws. NourishedRx will process requests in accordance with the law applicable to the requesting Individual and the Personal Information at issue.

12. Cambios en nuestra política de privacidad

Actualizamos esta declaración de privacidad anualmente. Cuando lo hagamos, también revisaremos la fecha de «última actualización» que aparece en la parte superior de la declaración de privacidad. En el caso de cambios importantes en esta declaración de privacidad, notificaremos a los usuarios mediante un aviso destacado en la página de inicio del sitio web de NourishedRx o enviándoles una notificación directamente a los usuarios. Alentamos a los usuarios a revisar esta declaración de privacidad periódicamente para mantenerse informados sobre cómo estamos ayudando a proteger la información personal que recopilamos. El uso continuo de nuestros servicios por parte de un usuario constituye la aceptación de esta declaración de privacidad y de cualquier actualización.

14. Policy on Children's Information

Our Services are not directed at children. We do not knowingly collect personally identifiable information from anyone under the age of 13, including through the AI Chatbot. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us through one of the methods provided in this Privacy Policy. If we become aware that we have collected Personal Information from children without verification of parental consent, we will take reasonable steps to remove that information from our servers.

For more information about the Children’s Online Privacy Protection Act (“COPPA”), which applies to websites that direct their services to children under the age of thirteen (13), please visit the Federal Trade Commission’s website: https://www.ftc.gov/business-guidance/resources/complying-coppa-frequently-asked-questions

15. Changes to Our Privacy Policy

We update this privacy statement annually. When we do, we will also revise the "last updated" date at the top of the privacy statement. For material changes to this privacy statement, we will notify users either by placing a prominent notice on the homepage of the NourishedRx website, by sending users a notification directly, by an alert through the Services, or as otherwise required by applicable law. We encourage users to review this privacy statement periodically to stay informed about how we are helping to protect the personal information we collect. A user’s continued use of our services, including the AI Chatbot, constitutes a user’s agreement to this privacy statement and any updates.