NavioMD Privacy Policy

NavioMD Privacy Policy
Effective Date: April 11, 2025

Last Date Updated: April 18, 2025

Definitions
Introduction
Limitations on Use by Minors & Children’s Privacy
Protected Health Information (PHI) & State‑Specific Health Data
Information We Collect
How We Use Your Information
Disclosure of Your Information
Your Choices & Controls
Browser, Cookie & Tracking Controls
Data Retention
Security Measures
International Data Transfers
Vendor & Third‑Party Links
Our Responsibilities & HIPAA Compliance
Transactions & Payment Data
Jurisdictional Matters
Your State Privacy Rights
Data Breach Notification
Changes to This Policy
Contacting Us

1. Definitions

Personal Information
Any information that identifies or can reasonably be linked to an individual.
Health Information
Includes medical history, treatment details, prescriptions, lab results, and related data.
Platform/Services
NavioMD’s websites, mobile apps, and related digital offerings.
Care Providers
Our clinical and pharmacy partners (e.g., Qualiphy, The Pharmacy Hub).

2. Introduction

NavioMD Inc. and its subsidiaries (“NavioMD,” “we,” “us,” or “our”) operate the NavioMD Platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your Personal and Health Information. By accessing or using our Services, you consent to these practices.

3. Limitations on Use by Minors & Children’s Privacy

Services are intended for users 18 years or older.
We do not knowingly collect data from anyone under 18 without verified parental consent.
If you believe we have collected data from a child under 13 without consent, contact us to have it deleted.

4. Protected Health Information (PHI) & State‑Specific Health Data

NavioMD is not a HIPAA‑covered entity, but we and our Care Providers comply with HIPAA as Business Associates where applicable.
We also adhere to state laws, including CMIA (CA), My Health My Data (WA), VCDPA (VA), CPA (CO), and CT Data Privacy Act.
Basic account data (name, email, shipping address) is not PHI unless linked with health details.

5. Information We Collect

A. Information You Provide

Identity & contact details (name, DOB, email, address)
Medical history, treatment goals, lifestyle information
Government‑issued ID (for identity verification)
Payment details (handled by third parties)
Uploaded documents, photos, intake forms
Communications (chat, email, surveys)

B. Information Collected Automatically

IP address, device/browser identifiers
Usage and clickstream data
Geolocation (with consent)
Cookies, web beacons, email open tracking

C. Information from Third Parties

Social login data
Analytics providers, data brokers
Records from Care Providers (Qualiphy, The Pharmacy Hub)

D. Inferred Data

Preferences or interests derived from your activity

6. How We Use Your Information

Provide & Improve Services: telehealth, prescriptions, labs
Billing & Operations: payment processing, support
Research & Analytics: aggregate/de‑identified insights
Legal & Safety: comply with law, detect fraud, protect rights

7. Disclosure of Your Information

We may share your data with:

Care Providers & Pharmacies: Qualiphy, The Pharmacy Hub
Patient Experience & Support: Steer Health
Service Providers: payment processors (Stripe, Adyen), hosting, analytics
Marketing Partners: for promotions (with opt‑out)
Corporate Transactions: mergers, acquisitions, asset sales
Legal Authorities: subpoenas, public health reporting
Data Enrichment: hashed or de‑identified formats

8. Your Choices & Controls

Access & Portability: request copy of your data
Correction: ask to amend inaccurate info
Deletion: request erasure (subject to legal requirements)
Limit Use/Sharing: for treatment, payment, operations
Confidential Communications: specify alternative contacts
Opt‑out of Marketing/Sales: follow instructions in Section 9

To exercise any rights, email support@naviomd.com. We may verify your identity before fulfillment.

9. Browser, Cookie & Tracking Controls

Cookie Notice: full details at our Cookie Notice page
Browser Settings: disable or delete cookies
Global Privacy Control (GPC): honored where supported
Do Not Track (DNT): not recognized
Mobile Ad IDs: opt‑out via device settings

10. Data Retention

We retain data only as long as necessary to:

Provide Services
Comply with laws, tax, or accounting obligations
Resolve disputes and enforce agreements

Note: De‑identified data may be kept indefinitely for research.

11. Security Measures

Encryption: in transit (TLS) and at rest where feasible
Access Controls: role‑based, least privilege
Monitoring & Testing: regular vulnerability scans and audits
Employee Training: mandatory privacy & security training

No system is infallible; we mitigate risks but cannot guarantee absolute security.

12. International Data Transfers

Our Services are hosted in the U.S. By using them, you consent to transfer, storage, and processing of your data in the U.S. If you access from outside, you assume any additional privacy risks.

13. Vendor & Third‑Party Links

External Links: our Platform may link externally; we aren’t responsible for their practices.
Embedded Content: videos or widgets follow the provider’s policy.

14. Our Responsibilities & HIPAA Compliance

We notify you of any breach affecting your data per HIPAA and state laws.
We follow our Notice of Privacy Practices when acting as a Business Associate.

15. Transactions & Payment Data

All billing is processed by PCI‑compliant vendors (Stripe, Adyen). NavioMD never stores full card numbers.

16. Jurisdictional Matters

Our data practices are governed by U.S. law. By using our Services, you consent to U.S. jurisdiction as set forth in our Terms & Conditions.

17. Your State Privacy Rights

California (CCPA/CPRA): rights to know, delete, correct data; opt‑out of “sale”/“sharing”; non‑discrimination.
WA, VA, CO, CT, NV: similar rights.

To exercise rights, visit our Privacy Center or email support@naviomd.com.

18. Data Breach Notification

In the event of unauthorized disclosure, we will notify you and regulators per applicable laws, typically within 30 days of discovery.

19. Changes to This Policy

We may update this Policy at any time. When we do, we will:

Post the revised Policy with a new “Last updated” date.
Provide notice (e.g., email) if material changes occur.

Your continued use indicates acceptance.

20. Contacting Us

NavioMD Privacy Officer
300 S Pine Island Road, Suite 260
Plantation, Florida 33324
Phone: 1-877-276-2846
Email: support@naviomd.com

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