This Privacy Policy ("Privacy Policy") describes the data protection practices of MDLaunchr ("MDLaunchr," "we," "our," or "us") when you interact with us, our application(s), or our website(s). For the purposes of this Privacy Policy, "Personal Information" refers to any information that is linked or reasonably linkable to an identified or identifiable natural person.
We refer to the websites and other services provided by MDLaunchr together in this Privacy Policy as the "Services." This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined here have the meanings assigned to them in the Terms of Use.
If you are a California resident, please review the section on privacy information for California residents below for state-specific rights.
Please read this Privacy Policy carefully to understand how we handle your information. If you do not agree to this Privacy Policy, please do not use the Services.
We obtain Personal Information about you through the means discussed below when you use the Services. We need certain types of Personal Information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, the Services may not function as intended.
1. Information you provide to us
We collect Personal Information that you provide directly to us, for example through:
- Account and product registration and administration of your account
- Processing your orders and requests for treatment
- Questions, communications, or feedback you submit to us via forms or email
- Requests for customer support and technical assistance, including through online chat
- Uploads or posts to the Services
- Employment applications you submit
The specific types of Personal Information we collect depend on the Services you use, how you use them, and the information you choose to provide. They may include:
- Name, address, telephone number, date of birth, and email address
- Information about your medical conditions, treatment options, physician referrals, lifestyle and personal preferences, prescriptions, genetics, medical photos, and lab results or other related health information, such as your physical and emotional characteristics
- Log-in credentials if you create an account
- Billing information, such as shipping address, credit or debit card number, verification number, and expiration date, collected by our payment processors on our behalf
- Identity verification information (for example, a driver's license or other government-issued ID card or number) and your signature if required for notarization
- Information about purchases or other transactions with us
- Information about your customer service and maintenance interactions with us
- Demographic information such as your gender, race or ethnicity, age, marital status, and number of children, in connection with the Services
- Information about others, such as if you share a family member's or friend's email address or contact information to allow access to your information or name them as an emergency contact
- User-generated content you post in public online forums on our Services or share with other users
- Any other information you choose to provide directly to us in connection with your use of the Services
2. Information we collect through automated means
We collect certain information about your use of the Services and the devices you use to access them. We and our service providers (third-party companies that work on our behalf) may use a variety of technologies, including cookies, SDKs, and similar tools, to assist in collecting this information.
Our websites. When you use our website and app, we collect and analyze information such as your IP address, device types, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, app usage, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our Services, the date and time you used the Services, error logs, and other similar information.
Location information. When you use the Services, we and our service providers may automatically collect general location information (for example, your IP address, city, state, or postal code) associated with your device. With your permission, we may also collect precise location information from your device.
Information we receive from other sources. We work closely with third parties (including, for example, physicians, medical professionals, and pharmacies that help provide the Services, as well as advertising networks, analytics providers, marketing partners, and search information providers). Such third parties will sometimes provide us with additional Personal Information about you.
In connection with providing you with the Services, we may use your Personal Information for our business purposes to:
- Carry out, improve, and manage the Services and, as applicable, facilitate the provision of health care services to you by physicians or other health care providers, and ensure those providers have the services and support necessary for health care operations
- Engage in internal research to understand the effectiveness of our Services, improve them, and better understand our user base; if we publish or provide the results of this research to others, it will be presented in de-identified and aggregate form so that individual users cannot be identified
- Communicate with you about the Services, your use of them, or your inquiries, and send you communications on behalf of physicians or other health care providers using the Services
- Communicate with you, in accordance with applicable legal requirements, by email, postal mail, or phone about surveys, promotions, special events, or our products and Services and those of our subsidiaries, affiliates, parent companies, and third-party partners
- Provide you with technical support and customer service and troubleshoot technical issues or errors
- Verify your identity and administer your account, including processing your payments, fulfilling your orders, and verifying the authenticity of your government-issued identification photo
- Present content from our Services in the most effective manner for you and your device, allow you to participate in interactive features when you choose to, and keep our Services safe and secure
- Provide you with more relevant advertisements and personalized content, and measure or understand the effectiveness of advertising and content we serve to you and others
- Help us better understand your interests and needs, such as by analyzing and researching use of the Services
- Comply in good faith with any procedures, laws, and regulations that apply to us where it is necessary for our legitimate interests or those of others
- Establish, exercise, or defend our legal rights where necessary for our legitimate interests or those of others, such as protecting against malicious, fraudulent, or illegal activity
Combined information. For the purposes discussed in this Privacy Policy, we may combine the Personal Information we collect through the Services with information we receive from other sources, both online and offline, and use and share that combined information in accordance with this Privacy Policy.
Aggregate and de-identified data. We may aggregate and/or de-identify information collected through the Services so that it can no longer reasonably be linked to you or your device and is no longer considered Personal Information ("Aggregate/De-Identified Information"). We may use Aggregate/De-Identified Information for any purpose, including research and marketing, and may share it with third parties, including advertisers, promotional partners, and sponsors.
1. Online analytics
We may use third-party web analytics services (such as Google Analytics, including Google Signals, Google User-ID, and other Google Analytics features, and Mixpanel) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. If you have a Google account with personalized advertising enabled, Google Signals lets Google gather analytics and engagement information for us across the devices you use to access the Services.
To prevent Google from using your information for analytics, including cross-device tracking for personalization, you can install the Google Analytics Opt-out Browser Add-on. To opt out of Google Signals, open your device's Google settings, select "Ads," and turn on "Opt out of Ads Personalization." You may also be able to disable cross-device tracking through your Android or Apple device settings.
If you receive email from us, we may use analytics tools such as clear GIFs to capture data such as when you open our message or click on links or banners it contains. This data lets us gauge the effectiveness of our communications and marketing campaigns.
2. Online advertising
The Services may integrate third-party advertising technologies (for example, ad networks and ad servers such as Facebook, Google Ads, TikTok, Criteo, and others) that use cookies, pixels, and other technologies to deliver relevant content and advertising for our products on the Services, on other websites you visit, and in other applications you use. The ads may be based on factors such as the content of the page you are visiting, information you enter such as your searches, demographic data, and other information we collect from you, and on your current activity or your activity over time and across other websites and online services.
We sometimes provide our customer information (such as email addresses) to service providers, who may "match" this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs to provide you with more relevant ads when you visit other websites and mobile applications. We may also share customer information such as your email address with third-party advertising networks that use it to better target advertising to you regarding our products and services, as well as other products and services, as you browse the internet.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that non-affiliated third-party advertising networks may place on the device you use to access the Services. You can adjust your advertising preferences with these providers directly. We do not control these opt-out links, whether they change over time, or whether any company chooses to participate in the industry opt-out programs listed here, and we are not responsible for choices you make related to third-party links available through the Services.
If you exercise the opt-out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.
3. Mobile advertising
When using mobile applications from us or others, you may receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements in mobile applications or for mobile application analytics. Each operating system (iOS, Android, and Windows) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the platform operator lets you manage personalized in-application advertisements, so contact the platform provider or review its support materials and device settings to opt out.
4. Notice concerning Do Not Track
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, which is why we provide the opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. We do strive to recognize universal opt-out signals where legally required.
We may share your information for our business purposes in the following ways:
- Affiliates and subsidiaries. We may share information we collect within our family of companies to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance your customer experience.
- Health care providers and services. We share your information with third-party health care providers (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment, or health care operations purposes, including pharmacy services, upon your request.
- Service providers. We provide access to or disclose your Personal Information to select third parties who use it to perform services on our behalf, including billing, content and service enhancements, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, auditing, consulting, and legal services. These entities may include health care organizations, pharmacies, and other third parties we use to support our business or the administration of the Services.
- Advertising networks. See the online advertising section above for how we share information with advertising partners.
- Joint product and marketing partners. Entities that jointly offer or provide services or products with us collect and use data in accordance with their own terms and privacy policies.
- Protection of the company and others. By using the Services, you acknowledge and agree that we may access, retain, and disclose the Personal Information we collect and maintain about you if required to do so by law or in a good-faith belief that doing so is reasonably necessary to: (a) comply with legal process such as a subpoena or court order; (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property, or personal safety of MDLaunchr, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, spam and malware prevention, and similar purposes.
- Business transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, including in contemplation of them, user Personal Information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer Personal Information, including your email address, would likely be one of the transferred business assets. If such a transfer is subject to additional mandatory restrictions under applicable law, we will comply with them.
- Public forums and user interactions. Certain features of our Services let you share comments publicly or with other users. Personal Information you post publicly is not confidential, and we may use it for any purpose, including testimonials and other marketing materials. If you submit a product review on one of our websites, we may display it, along with the name provided, on our websites and on third-party websites. Information you post openly will be available to the users you shared it with and potentially the public at large, and may be accessible through third-party search engines. Please take care when using these features; we are not responsible for how others use information you share with them through the Services.
- Testimonials and reviews. We may, directly or indirectly, solicit or invite you to submit product or service reviews, whether written, video, or otherwise. If you choose to submit information in response, including your name, likeness, image, or review, you consent to our use of it in marketing materials or testimonials on our website or third-party websites.
- Consent. We may also disclose your information in other ways you direct us to and when we have your consent.
- Aggregate and de-identified information. We reserve the right to create Aggregate/De-Identified Information from data collected through the Services; our disclosure of it is at our discretion.
Depending on the state in which you live, you may have legal rights with respect to your information. The types of requests you may be able to make include:
- Information about the categories of information we process, our uses of it, our sources for it, and our disclosure of it
- Access to the information we have collected about you and a copy of certain information in a portable format
- Correction of certain information we have about you
- Deletion of the information we have about you
You may make a request by emailing hello@whitelabelclinic.com. Before we disclose, correct, or delete information in response to a request, we will need to verify your identity, and depending on the nature of the request we may contact you for further information. We will never ask you for sensitive personal or financial information when verifying your identity, and no employee will ask you for your password. If you are an authorized agent submitting a request on someone's behalf, we may require proof of the written authorization you have received.
Certain information may be exempt from such requests under applicable law, for example if the request would prevent us from completing a transaction you initiated, interfere with our legal obligations, affect legal matters including another customer's rights to data in their account, or if we cannot verify your identity, or if compliance is not legally required and would involve disproportionate cost or effort. In any event, we will respond within a reasonable timeframe and provide an explanation. If we deny your request in whole or in part, the laws in your jurisdiction may give you the right to appeal, and we will tell you how in our response. You may also have the right to lodge a complaint with a supervisory authority.
We will not discriminate against anyone who makes a rights request, but in some cases we will not be able to provide our Services without the information in question.
Opting out of the sale of information and targeted advertising
As explained in the online analytics and advertising section above, and subject to applicable law, we allow third parties to receive certain information such as cookies, IP address, device identifiers, hashed contact information, browsing behavior, and other activity to enable the delivery of targeted advertising to you. These activities may qualify as the "sale" of personal information or the "sharing" or processing of personal information for targeted advertising, as defined in applicable law.
Residents of certain states may opt out of the sale of personal information, or the sharing or processing of their personal information through cookies, pixels, and similar tools for targeted advertising. If you have a legally recognized browser-based opt-out preference signal turned on (such as Global Privacy Control), we recognize it in accordance with, and to the extent required by, applicable law. A cookie blocker may hide this tool. You can also use an authorized agent to submit an opt-out request on your behalf if you give the agent written permission; we may require proof of that authorization.
In addition to advertising activities that use cookies and pixels, we may share user email addresses with advertising partners to provide you with more relevant advertising. To opt out of this activity, email hello@whitelabelclinic.com. If you opt out, you may still receive advertising; it just may not be tailored to your interests. If you use different browsers, devices, or services, you will need to opt out on each one where you want your choice to apply.
Your data rights
You have rights to your data: the right to be informed about how we use it, and the rights to access, rectify, erase, and restrict processing. You have the right to data portability and the right to object to data transfer or usage. To exercise these rights, or for questions about the use of your data, contact us using the information at the end of this policy.
Your marketing choices
You may instruct us not to use your contact information to contact you by email, postal mail, or phone about products, services, promotions, and special events by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions at the bottom of the email. Regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law; for example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.
Sensitive data opt-out and opt-in right
To provide you with more relevant online advertising about our products and services, we may use information about the treatments you have requested or received and similar information. This may include processing of information that is considered "sensitive data" or "sensitive personal information" under applicable laws, such as health information and information about sex life or sexual orientation. You have the right to limit our use of sensitive data to purposes other than providing the services or goods you request, or as otherwise permitted by law, including our and our partners' processing of sensitive data for tailored advertising. To opt out, email us or use the Global Privacy Control described above. Depending on your jurisdiction, we may ask for your consent before using your sensitive data, and if you consent and later change your mind, you can opt out at any time.
Children's data
Our Services are not directed to or intended for anyone under the age of 16, and we do not knowingly collect Personal Information from anyone under 16. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete it. If you become aware that a child under 16 has provided us with Personal Information, please contact us as described below.
This Notice of Privacy Practices ("Notice") describes how we may use and disclose your protected health information ("PHI") to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by law. It also describes your rights regarding your PHI. We are required by law to maintain the privacy of your PHI, to provide you with this Notice of our legal duties and privacy practices, and to abide by its terms.
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security processes and standards, of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other hardware and software, and any other third-party application, website, or service that our Services may link to. These third parties may gather information from or about you, and we have no control over their privacy practices. Their collection, use, and disclosure of your information is subject to their privacy policies, not this one, and we urge you to read them.
Uses and disclosures of PHI
We may use and disclose your PHI for the following purposes:
- Treatment: to provide, coordinate, or manage your health care and related services, including communication with other health care providers about your treatment and coordinating your care with them.
- Payment: to obtain payment for health care services provided to you, which may include contacting your insurance company to verify coverage, billing and collection activities, and sharing PHI with other health care providers, insurance companies, or collection agencies.
- Health care operations: quality assessment and improvement, case management, accreditation, licensing, credentialing, and conducting or arranging medical reviews, audits, or legal services.
- As required by law: when federal, state, or local law requires it.
- Public health and safety: to prevent or control disease, injury, or disability; to report child abuse or neglect; to report reactions to medications or problems with products; and to notify people who may have been exposed to a communicable disease or may be at risk of spreading one.
- Health oversight activities: to health oversight agencies for activities authorized by law, such as audits, investigations, inspections, and licensure.
- Judicial and administrative proceedings: in response to a court or administrative order, subpoena, discovery request, or other lawful process.
- Law enforcement: for law enforcement purposes, such as reporting certain types of wounds or injuries, or complying with a court order, warrant, or other legal process.
- Research: when the research has been approved by an institutional review board and privacy protections are in place.
- Organ and tissue donation: if you are an organ donor, to organizations that handle organ procurement, transplantation, or donation.
- Workers' compensation: for workers' compensation or similar programs that provide benefits for work-related injuries or illnesses.
- Military and veterans: if you are a member of the armed forces, as required by military authorities.
- Inmates: if you are an inmate, to the correctional institution or law enforcement official having custody of you.
Your rights regarding PHI
- Right to inspect and copy: you may inspect and copy the PHI we maintain, with certain exceptions. Submit a written request to our Privacy Officer; we may charge a reasonable fee for copying, mailing, or other supplies.
- Right to amend: you may request an amendment to your PHI if you believe it is incorrect or incomplete. Submit a written request specifying the information you believe is incorrect and why. We may deny the request if we believe the information is accurate and complete, or if we did not create it.
- Right to an accounting of disclosures: you may request an accounting of disclosures of your PHI made in the past six years, except for disclosures made for treatment, payment, or health care operations and certain other disclosures.
- Right to request restrictions: you may request a restriction on our use or disclosure of your PHI for treatment, payment, or health care operations. We are not required to agree, but will consider it.
- Right to request confidential communications: you may request that we communicate with you about your PHI in a certain way or at a certain location.
- Right to a paper copy of this Notice: you may receive a paper copy even if you have agreed to receive it electronically.
- Right to be notified of a breach: you will be notified if we discover a breach of your PHI.
Transmission of PHI
We are committed to protecting the privacy of your PHI and will ensure that any electronic transmission of PHI subject to HIPAA complies with the HIPAA Privacy Rule (45 CFR Part 164). This includes the use of secure transport encryption (SSL/TLS or equivalent) for the transmission of PHI, and adherence to applicable security standards for online transmissions of PHI.
Changes to this Notice
We reserve the right to change this Notice, and the revised Notice will be effective for PHI we already hold about you as well as information we receive in the future. The current Notice is posted on our website and carries its effective date at the top.
Complaints
If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the Secretary of the U.S. Department of Health and Human Services. You will not be retaliated against for filing a complaint.
State-specific PHI rights
Certain states have additional privacy protections that apply to your PHI. California residents, for example, have the additional rights listed in the California section below. If you reside in a state with additional protections, you may have further rights related to your PHI; consult your state's privacy laws or contact our Privacy Officer for more information. In addition to the practices described in this Notice, we comply with applicable state-specific privacy laws related to PHI.
This Notice is provided in accordance with the Department of Health and Human Services model Notice of Privacy Practices for Protected Health Information and applies across all U.S. states. To exercise any of your rights, or if you have questions about this Notice or our privacy practices, contact our Privacy Officer using the information at the end of this policy.
We take a variety of technical and organizational security measures designed to protect both your PHI and your Personal Information against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is completely secure. You acknowledge and accept that we cannot guarantee the security of information transmitted to, through, or on our Services or via the internet, and that any such transmission is at your own risk. Where we have given you, or you have chosen, a password that enables you to access the Services, you are responsible for keeping it confidential, and we ask you not to share it with anyone. Information you share in public areas may be viewed by any user of the Services.
If you are a California resident, California law requires us to provide some additional information about how we collect, use, and share your "personal information" as defined in the California Consumer Privacy Act ("CCPA"). Some of the information we collect through the Services, such as medical information, is subject to health data privacy laws and is therefore not subject to the CCPA.
Categories of personal information we collect and disclose
- Identifiers and contact information (for example, name, address, email address, account names, government-issued IDs and numbers)
- Commercial and transactional information (for example, information about your purchases)
- Financial information (for example, credit card information collected by our payment processors)
- Internet or other network or device activity (for example, IP address, browsing history, app usage)
- Geolocation information (general location, and precise location with your permission)
- Demographic and statistical data (for example, your gender and interests based on the products and services you use)
- Physical characteristics (for example, photos and videos of you)
- User-generated content (for example, information you choose to post in our online forums)
- Customer service data (for example, information you provide through a chat or call with us)
Your California privacy rights
The CCPA allows California residents to ask us to: inform you about the categories of personal information we collect or disclose about you, the categories of sources, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it; provide access to and/or a copy of certain information we hold about you; and delete certain information we have about you. The CCPA also gives you the right not to be discriminated against for exercising your rights.
Certain information may be exempt from such requests under California law; for example, we need certain information to provide the Services to you. We will take reasonable steps to verify your identity before responding. To exercise any of your rights under California law, email hello@whitelabelclinic.com and include your full name, email address, and residential address associated with your use of our Services, along with the rights you would like to exercise.
Sale of personal information
The CCPA requires companies that "sell" (as defined in the CCPA) personal information to provide notice and an opportunity to opt out. Like many companies with an internet presence, we work with third parties that provide marketing and advertising services, including interest-based advertising, and these third parties may place tags, pixels, cookies, beacons, and similar tracking mechanisms on our website and app and collect your online identifiers. Because of the CCPA's broad definitions of "sale" and "personal information," making certain online identifiers available to these companies may be considered a "sale." To opt out of sharing your information with participating third parties for interest-based advertising, use the industry opt-out tools below. These opt-outs are device- and browser-based, so you will need to opt out on each device and browser you use.
As discussed in the online advertising section, we may also share information such as your email address with third-party advertising networks, which may be considered a "sale" under the CCPA. To opt out, email hello@whitelabelclinic.com.
Shine the Light disclosure. California's "Shine the Light" law gives residents the right, under certain circumstances, to request information about how we share certain categories of personal information with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
Additional California rights regarding PHI
- Right to access: California residents may request access to their PHI in a readily usable electronic format, along with any additional information required by California law, by submitting a written request to our Privacy Officer.
- Right to restrict certain disclosures: California residents may request restrictions on certain disclosures of their PHI to health plans if they paid out of pocket in full for a specific health care item or service.
- Confidentiality of Medical Information Act (CMIA): California residents are protected by the CMIA, which provides additional privacy protections for medical information. We comply with the CMIA in addition to HIPAA and will obtain written consent before disclosing certain information as California law requires.
- Marketing and sale of PHI: California residents may request that their PHI not be used for marketing purposes or sold to third parties without their authorization.
- Minors' rights: if you are under 18, you may request that certain information related to sensitive services, such as reproductive health, mental health, or substance use disorder treatment, not be disclosed to your parent or guardian without your consent.
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time we retain information depends on the purposes for which we collected and use it and on what applicable law requires.
We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically; the date it was last revised is shown at the top of this page. If we make a material change, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our websites after such amendments, and notice where applicable, will be deemed your acknowledgment of the changes.
If you have any questions about this Privacy Policy or our privacy practices, or wish to reach our Privacy Officer, please contact us at:
If you are experiencing a medical emergency, you should dial 911 immediately. The content of this website is for informational purposes only and does not constitute professional medical advice, diagnosis, treatment, or recommendations of any kind. The website is not intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease. Always seek the advice of a board-certified medical practitioner or other qualified health care provider with any questions or concerns about your individual needs and any medical conditions. Visiting the website or registering an account does not create a physician-patient relationship. Reliance on the website without further consultation with a medical practitioner is solely at your own risk.
Questions about compliance more broadly? See our compliance and marketing guidance.