Privacy Policy

IMPORTANT: Our Notice of Privacy Practices is a separate document that governs how protected health information ("PHI") about you may be used and disclosed in connection with healthcare services provided by affiliated professional entities, in accordance with the Health Insurance Portability and Accountability Act ("HIPAA"). This Privacy Policy covers information collected through our Site and does not replace or limit the Notice of Privacy Practices. For healthcare services facilitated through OpenLoop Healthcare Partners, please review: OpenLoop Health’s NOPP. For healthcare services facilitated through ADPS Network, PLLC, please review: ADPS Network’s NOPP.

I. Introduction

This Privacy Policy ("Privacy Policy") describes how SteadiCare LLC ("SteadiCare," "we," "us," or "our") collects, uses, and discloses information about you through your use of our website at steadicarehealth.com, including all subdomains and associated pages (the "Site"), and through email, text, and other electronic communications between you and SteadiCare. This Privacy Policy does not apply to information collected by third parties, including through any application, content, or advertising that may link to or be accessible from the Site.

SteadiCare is a management services organization ("MSO") that provides administrative, advertising, marketing, and technology services to affiliated licensed professional entities that deliver healthcare services to patients. This Privacy Policy applies to information collected through the Site and in connection with our administrative services. It does not govern protected health information ("PHI") collected in the context of clinical care, which is separately governed by the applicable affiliated professional entity's Notice of Privacy Practices.

In connection with the administrative and operational services SteadiCare provides to affiliated professional entities, SteadiCare may receive, maintain, or process protected health information ("PHI") on their behalf as a Business Associate, as that term is defined under the Health Insurance Portability and Accountability Act ("HIPAA"). Any PHI handled by SteadiCare in this capacity is governed by the applicable Business Associate Agreement and the HIPAA Privacy and Security Rules. This Privacy Policy does not alter or supersede those obligations.

All capitalized terms not defined in this Privacy Policy have the meanings assigned in our Terms of Service. By accessing or using the Site, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Policy and our Terms of Service. If any term is unacceptable to you, please do not use the Site or provide any personal information. This Privacy Policy may be updated from time to time; your continued use of the Site after any changes constitutes acceptance of the revised policy. Please review this Privacy Policy periodically for updates.

II. Information We Collect and How We Collect It

A. Information You Provide to Us

We collect information that you provide directly when you use the Site or communicate with us, including:

• Personal identifiers such as your name, mailing address, email address, telephone number, date of birth, and gender.
• Health-related information you share through intake forms, questionnaires, or electronic communications, including clinical history, current medications, and condition information.
• Account and subscription information, including preferences and settings.
• Payment and billing details. SteadiCare does not collect or store your full credit card information. Payment data is transmitted via encrypted connection to Stripe, our third-party payment processor. For more information, please visit stripe.com/privacy.
• Records and copies of your correspondence, including email addresses and message content, when you contact us or report an issue.
• Testimonials or feedback you choose to submit. If a testimonial is published, only your first name will be displayed. Please do not submit testimonial content you would not want others to see or share.
• Search queries and any other information you choose to provide when completing forms, requesting services, or contacting us.

B. Information Collected Automatically

As you navigate and interact with the Site, we may automatically collect certain information, including:

• Usage and traffic data, including pages visited, time spent on pages, links clicked, and referring URLs.
• Device and connection information, including your IP address, browser type, operating system, and internet service provider.
• Geographic location data derived from your IP address.
• Information collected through cookies, web beacons, pixel tags, and similar tracking technologies.

We use this data to operate and improve the Site, analyze usage trends, personalize your experience, and maintain security.

Cookies. Cookies are small data files placed on your device that help us recognize returning visitors, remember preferences, and gather usage analytics. You may configure your browser to refuse cookies or alert you when they are being sent; however, doing so may limit access to certain Site features.

Web Beacons and Pixel Tags. Certain pages and emails may contain web beacons or pixel tags — small electronic files that help us measure user engagement, count page visits, and assess content performance.

Artificial Intelligence. We may use AI-assisted technologies to improve the efficiency, quality, and personalization of our services, including automated data analysis and customer support tools. Data processed for these purposes is handled consistently with this Privacy Policy.

Global Privacy Control. Our Site is designed to recognize and respond to Global Privacy Control ("GPC") signals, which indicate that you do not want your personal information sold or shared for cross-context behavioral advertising.

C. Information We Receive From Third Parties

We may receive information about you from third parties, including:

• Affiliated professional entities and their clinical personnel who coordinate care or communicate with SteadiCare on your behalf.
• Partner pharmacies and laboratories involved in your treatment.
• Analytics providers, advertising networks, and other business partners.
• Payment processors and fraud-prevention services.

We may combine information received from third parties with information you provide directly and information we collect automatically, and use the combined data as described in Section III.

III. How We Use Your Information

We use information we collect for the following purposes:

• To operate, maintain, and improve the Site and our services.
• To process your enrollment, subscription, and payment transactions, and to administer your account.
• To coordinate administrative services and facilitate the delivery of healthcare services by affiliated professional entities.
• To communicate with you about your account, subscription, orders, and treatment-related matters, including appointment reminders, prescription updates, refill reminders, and wellness check-ins.
• To contact you by phone, email, or SMS/text message consistent with your communication preferences and applicable law, including the Telephone Consumer Protection Act ("TCPA").
• To deliver marketing communications, newsletters, and promotional offers where you have provided the required consent.
• To create de-identified or aggregated data — including website behavioral data, usage patterns, and population-level analytics — that cannot reasonably be used to identify you individually. We may use, analyze, license, or sell such de-identified or aggregated data to third parties for research, analytics, product development, or commercial purposes.
• To detect, investigate, and prevent fraud, security incidents, and unauthorized activity.
• To verify your identity and ensure the integrity of your account.
• To comply with applicable federal, state, and local laws, regulations, and legal process.
• To enforce our Terms of Service and other agreements and to protect the rights, property, or safety of SteadiCare, our users, or others.
• For any other purpose disclosed at the time of collection or with your consent.
• To measure the effectiveness of our advertising and communications and to better understand the demographics, interests, and behavior of our audience.

All of the above purposes exclude text messaging originator opt-in data and consent. SMS opt-in information will not be shared with any third party for marketing or advertising purposes.

IV. SMS Communications — SteadiCare Text Program

SteadiCare operates the SteadiCare Text Program, which delivers both care coordination messages and marketing communications via SMS. By opting in to our text program, you consent to receive recurring automated text messages from SteadiCare at the mobile number you provide. Messages may include appointment reminders, prescription and refill updates, care coordination notices, wellness check-ins, program updates, and promotional offers.

Message frequency varies. Message and data rates may apply depending on your wireless carrier.

To stop receiving messages, reply STOP to any message. You will receive a single confirmation, and no further texts will be sent. You may also submit opt-out requests by emailing support@steadicarehealth.com, and we will process them within ten (10) business days. For assistance, reply HELP to any message or contact us at support@steadicarehealth.com.

SMS opt-in data and consent status will not be shared with any third party for marketing or advertising purposes. We may share your mobile number and consent status solely with service providers who assist us in delivering messages — such as platform providers, wireless carriers, and SMS vendors — strictly for that purpose.

Consent to receive SteadiCare Text Program messages is not a condition of purchase or enrollment. Wireless carriers are not liable for delayed or undelivered messages.

V. Disclosure of Your Information

We may disclose information we collect or that you provide in the following circumstances:

• To affiliated professional entities and their clinical personnel — including physicians, nurse practitioners, and other licensed providers — who deliver healthcare services to you.
• To partner pharmacies and laboratories involved in your care, including Red Rock Compounding Pharmacy, Health Warehouse, Precision Medicine Pharmacy, and Triad Rx, as necessary to fulfill your prescriptions or coordinate your treatment.
• To service providers and contractors who support our operations, including technology vendors, analytics providers, email delivery services, customer support platforms, and payment processors.
• To Stripe and other third-party payment processors via encrypted connections for the purpose of processing your payments.
• To our affiliates and their employees for internal administrative and operational purposes.
• To a buyer, successor, or acquirer in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, in which your information may be among the assets transferred or disclosed.
• To comply with applicable law, legal process, or requests from governmental or regulatory authorities.
• To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
• To protect the rights, property, or safety of SteadiCare, our users, or others, including for fraud prevention and credit risk reduction purposes.
• For any other purpose disclosed at the time of collection or with your express consent.

We do not sell your personal information to third parties. We do not disclose mobile opt-in data or SMS consent information to third parties for marketing or promotional purposes.

We may disclose, license, or sell aggregated or de-identified information — including website analytics, usage trends, and population-level data — that cannot reasonably be used to identify you. We may share such data with third parties including researchers, analytics providers, pharmaceutical companies, and commercial partners without restriction.

VI. Your Privacy Choices

Cookies and Tracking Technologies. You may configure your browser to refuse cookies or to alert you when cookies are being sent. Disabling cookies may affect the functionality of certain Site features.

Do Not Track. We do not currently respond to "do not track" signals transmitted by web browsers, as no uniform industry standard for recognizing or honoring such signals has been established. We do, however, recognize and respond to Global Privacy Control ("GPC") signals as described above.

Marketing Emails. If you do not want to receive promotional emails from us, you may opt out by clicking the unsubscribe link in any marketing email or by contacting us at support@steadicarehealth.com. Note that this opt-out does not apply to transactional, account, or service-related communications.

SMS Messages. You may opt out of text messages at any time by replying STOP to any message or by contacting us at support@steadicarehealth.com.

Third-Party Advertising. You may opt out of interest-based advertising from members of the Network Advertising Initiative ("NAI") by visiting www.networkadvertising.org/choices.

Residents of certain states may have additional privacy rights. See Sections X and XI below.

VII. Data Security

We have implemented technical, administrative, and physical safeguards designed to protect your information from unauthorized access, use, disclosure, alteration, and loss.

Where you have been issued or have chosen a password to access certain parts of the Site, you are responsible for keeping that password confidential. Please do not share your password with anyone.

Unfortunately, no method of transmitting or storing information over the internet is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

When you access the Site or Services on a mobile device, there is a risk that certain information may be stored in an unencrypted state on your device. We implement technical safeguards designed to minimize this risk but cannot guarantee they will be fully effective in all circumstances. You are responsible for maintaining the physical security of your device and logging out of your account when not in use.

VIII. Third-Party Links and Services

The Site may contain links to, or integrations with, websites, platforms, and services operated by third parties. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their content, privacy practices, or data handling. We encourage you to review the privacy policies of any third-party site you visit.

STEADICARE DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES OR HOW THEY HANDLE YOUR PERSONAL INFORMATION. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE.

IX. No Services to Minors

SteadiCare does not knowingly collect personal information from, or direct services to, individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will take prompt steps to delete it. If you believe a minor has provided personal information to us through the Site, please contact us at support@steadicarehealth.com.

X. Your State Privacy Rights

Residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, Virginia, and other states with applicable consumer privacy laws may have certain rights regarding their personal information, which may include:

• The right to confirm whether we process your personal information and to access that information.
• The right to request deletion of your personal information, subject to certain legal exceptions.
• The right to correct inaccuracies in your personal information (may not apply in all states).
• The right to data portability — to receive a copy of your personal information in a portable format.
• The right to opt out of the sale or sharing of your personal information, and of profiling for decisions with legal or similarly significant effects (may not apply in all states).
• The right to limit or opt out of the processing of sensitive personal data.
• The right not to be discriminated against for exercising your privacy rights.

To exercise any applicable rights, please contact us at support@steadicarehealth.com. We will verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf; we may require documentation confirming that authorization. To appeal any decision on your request, follow the instructions provided in our response.

Please note that these rights may not apply to all information we collect. PHI governed by HIPAA, and medical information governed by applicable state law, are subject to separate legal frameworks. Please review the Notice of Privacy Practices of the applicable affiliated professional entity for information about your rights regarding protected health information.

XI. California Residents — Additional Rights Under the CCPA/CPRA

If you are a California resident, the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), provides you with additional rights regarding your personal information. This section supplements the rest of this Privacy Policy and applies only to California residents.

Note: The CCPA does not apply to PHI governed by HIPAA or "medical information" governed by the California Confidentiality of Medical Information Act ("CMIA"). For information about rights related to your health information, please review the applicable Notice of Privacy Practices.

Categories of Personal Information Collected. In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers (e.g., name, mailing address, email address, telephone number, IP address, cookies, and similar identifiers)
• Characteristics of protected classifications under California or federal law (e.g., age, gender)
• Commercial information (e.g., subscription and purchase history)
• Internet or electronic network activity information (e.g., browsing history, Site interactions, and search queries)
• Geolocation data (e.g., location derived from IP address)
• Health-related information (to the extent not governed by HIPAA or CMIA)
• Professional or employment-related information (e.g., occupation, if provided)
• Inferences drawn from the above to create a profile reflecting your preferences and interests

Right to Know. You may request information about the categories and specific pieces of personal information we have collected about you in the preceding 12 months, the sources of that information, the purposes for which we use it, and the categories of third parties with whom we share it.

Right to Delete. You may request that we delete personal information we have collected from you, subject to exceptions such as when the information is necessary to complete a transaction or comply with a legal obligation.

Right to Correct. You may request that we correct inaccurate personal information we maintain about you.

Right to Opt-Out of Sale/Sharing. While we do not sell personal information in the traditional sense, the CCPA defines "sale" and "sharing" broadly to include certain data disclosed to third parties for cross-context behavioral advertising. You may opt out of such sharing by using a GPC signal or by contacting us at support@steadicarehealth.com. You may also manage your cookie and tracking preferences at any time through the consent banner displayed when you first visit our Site.

Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights, including by denying services, charging different prices, or providing a different level of quality.

To submit a CCPA request, contact us at support@steadicarehealth.com. We will verify your identity before processing any request. You may designate an authorized agent to act on your behalf by providing written authorization and confirming your identity with us directly.

XII. Changes to This Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time. When we make material changes, we will post the updated policy on this page with a revised "Last Updated" date, and we may provide notice through the Site or by email. Your continued use of the Site following any changes constitutes your acceptance of the revised Privacy Policy. You are responsible for periodically reviewing this Privacy Policy for updates.

XIII. Contact Us

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

SteadiCare LLC

support@steadicarehealth.com

3801 N Capital of Texas Hwy
Ste E240-4079
Austin, TX 78746