AUTHORIZATION FOR USE AND DISCLOSURE YOUR INFORMATION

Last updated: August 27, 2026

  1. INTRODUCTION

The purpose of this online Populus Media privacy policy (this “Privacy Policy”) is to describe how Populus Media, Inc. (“Populus Media”) collects, uses and shares information about you through our online interfaces and digital properties (e.g., websites) owned and controlled by Populus Media, including the website located at www.populus-media.com, www.populushealthtech.com, and any other website, app or platform where this Privacy Policy is presented. Populus Media respects your privacy and is committed to protecting it as outlined in this Privacy Policy. If you do not agree with our policies and practices, you may not use our services, including any “Digital Services” as defined in our Terms of Use (referenced below). By accessing or using the Digital Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Digital Services after we make changes is deemed to be acceptance of those changes. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us as described at the end of this Policy.

Our Privacy Policy explains:

  • Information That We Collect
  • How We Use and Share Your Information
  • Access to Your Information and Choices
  • Security of Your Information
  • Consent to Processing of Personal Data in United States
  • Changes to Our Privacy Policy
  • State Laws
  • Questions and How Contact Us

Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Digital Services as defined in our Terms of Use (referenced below). The Digital Services also contain links to third-party sites that are not owned or controlled by Populus Media. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Digital Services and to read the privacy statements of each and every website that collects personal information.

Terms of Use. Please note that your use of the Digital Services is also subject to our Terms of Use, which is accessible at www.populus-media.com.

  1. INFORMATION THAT WE COLLECT

Information You Provide to Us

We collect information you provide to us when you seek to use any of the Digital Services as defined in our Terms of Use), request information from us, contact customer support, or otherwise communicate with us or use the Digital Services in a commercial manner. This information may include:

  • Name
  • Address
  • Email address
  • Telephone number
  • Payment information (credit card or debit card number, expiration date and credit card security code – for payment purposes on behalf of telehealth clients of ours, but we do not store and save credit card or other payment information after payment is made).
  • Date of birth
  • User name and password
  • Medical history, answers to intake questionnaires, and other health information

 

Furthermore, if you are connected to a medical provider through our platform, you may also be asked to submit certain confidential information during the sign-up process, as well as demographic and other information relevant to diagnosis and treatment, such as lifestyle and general medical history (e.g. conditions, allergies etc.).

Information We Collect Automatically Through Your Use of the Digital Services

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Digital Services. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Digital Services analyze how users use the Digital Services. You can find out more about how Google uses data when you use the Digital Services by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). You will have the option to opt out via an unsubscribe link.  Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.

Information Collected Through Cookies and Similar Technologies

The Digital Services and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information when you interact with the Digital Services through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you access the Digital Services again, the cookie allows the Digital Services to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Digital Services features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)

No Information from Individuals Under the Age of 18

If you are under the age of 18, please do not attempt to register for the Digital Services or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under 18, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please Contact Us as described below.

  1. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. We collect information from you and use the information to:

  • provide products and services that you order using the Digital Services;
  • provide information that you request from us;
  • contact you about our services or information you requested;
  • process credit card and debit card transactions;
  • to allow you to participate in interactive features of our services;
  • send you promotional materials or advertisements about our products and services, as well as new features and offerings;
  • enforce our Terms of Use or other legal rights and remedies;
  • administer surveys;
  • provide interest-based targeted advertising to you; and,
  • any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

 

Sharing with Third Parties.

Healthcare Providers. We share your personal information with various healthcare affiliates, e.g. pharmacies, doctors and relevant medical staff in connection with your diagnosis and treatment. Pursuant to the Health Insurance Portability and Accountability Act of 1996 and associated laws and regulations, we function as a “business associate” to the telehealth providers made available to you through the Digital Services. This means we comply with the telehealth providers’ Notice of Privacy Practices provided to you by the providers with respect to your protected health information (“PHI”) that we receive, create, or maintain on behalf of the providers. The only exception to the foregoing is with respect to information (which may include PHI) that we obtain your specific authorization to use and disclose as described in the authorization.

Vendors and Services Providers. We may provide information to third-party vendors and service providers that help us operate and manage the Digital Services, process orders, and fulfill and deliver products and services that you purchase or request from us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Corporate Affiliates. We may share de-identified and aggregated information with our other companies and people with whom we do business (namely, our customers or other affiliates).

Advertising. We may use how you browse and shop in order to show you ads for Populus Media or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by Populus Media.

We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. Currently, the Digital Services do not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. 

Text Messaging Opt-In Data. We do not sell or share your text messaging opt-in data or consent with third parties for their marketing purposes. We may share this information with service providers that help us provide text messaging services.

Social Media. If you use third-party services, such as Facebook, Google, or Twitter, to share information about your experience of the Digital Services with others, these third-party services may be able to collect information about you, including information about your activity on the Digital Services, and they may notify your connections on the third-party services about your use of the Digital Services, in accordance with their own privacy policies.

Public Posts and Activities. If you choose to engage in public activities on the Digital Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas. Any user posting in these public areas understands and acknowledges that there is no expectation of privacy for the information in these public areas.

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of Populus Media when we have your consent to do so.

Legal Proceedings. We will share personal information with third-party companies, organizations or individuals outside of Populus Media if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
  • Enforce applicable Terms of Use, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security or technical issues.
  • Protect against harm to the rights, property or safety of Populus Media, our users, customers or the public as required or permitted by law.

 

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Digital Services to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

  1. ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your online account by the Contact Us described below.

  1. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please note that emails and other communications you send to us through the Digital Services are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

  1. CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

This Site is intended for use only by residents of the U.S. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide the Digital Services, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing the Digital Services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

  1. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

  1. STATE LAW COMPLIANCE

For individuals in Washington and Nevada, please refer to our Consumer Health Data Privacy Policy for additional information about the processing of your Personal Data that is “consumer health data” as defined under those laws.

You may have rights under other state consumer privacy laws, including California, Colorado, Connecticut, Maryland, Oregon, Texas, Utah, and Virginia. Please contact us if you have questions or would like to exercise a right under these laws.

  1. QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us by emailing us at support@populus-media.com, or contacting us by US postal mail at the following address:

Populus Media, Inc.
33 West 60th St.
Suite 200
NY, NY,10023

Consumer Health Data Privacy Policy

Last Updated: March 25, 2025

This notice supplements our Privacy Policy and applies to personal data defined as “consumer health data” subject to state laws, such as the Washington State My Health My Data Act (MHMDA) and Nevada’s Consumer Health Data Privacy Law.

Consumer Health Data We Collect

As described in the Privacy Policy, the data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Digital Services and features you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data.

Examples of consumer health data may include:

  • Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments (including surgeries, procedures, medications, or other interventions). For example, we may collect such information through intake questionnaire and improving product accessibility.
  • Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your health.
  • Other information that may be used to infer or derive data related to the above or other health information.

 

Sources of Consumer Health Data

As described further in our Privacy Policy, we collect personal data (which may include consumer health data) directly from you, from your interactions with the Digital Services, and from third parties

Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in our Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the Digital Services you have requested or authorized. This may include delivering and operating the Digital Services and their features, personalization of certain Digital Services features, ensuring the secure and reliable operation of the Digital Services and the systems that support them, troubleshooting and improving the Digital Services, and other essential business operations that support the provision of the Digital Services (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law – for example, for advertising or marketing purposes. See our Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

As described in our Privacy Policy, we may create aggregate/de-identified data from the information we collect through the Digital Services and our disclosure of such aggregate/de-identified data is in our discretion.

Our Sharing of Consumer Health Data

We may share each of the categories of consumer health data described above for the purposes described in our Privacy Policy. In particular, we may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any Digital Services you have requested or authorized, as described above.

We share your data with third parties when you tell us to do so. If you make a purchase, we will share information about the transaction as necessary to process the payment, including protection against fraud. And we may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

Third Parties with which We Share Consumer Health Data

As necessary for the purposes described above, we share consumer health data with the following categories of third parties:

  • Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to assist in protecting and securing our systems and services may need access to data to provide those functions.
  • Business partners. We may share consumer health data with other companies, for example, where you use a Digital Service that is cobranded and jointly operated with another company, or where you use our services to interact with another company.
  • Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
  • Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
  • Government agencies. We may disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
  • Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.

 

How to Exercise Your Rights

State laws like the MHMDA provide certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in our Privacy Policy. For example, depending on the Digital Service you use, you can access and make choices about your data through product controls. And if you want to access or control consumer health data processed by us that is not available via those tools or directly through the Digital Services you use, you can contact us at the contact information in the Privacy Policy.

If your request to exercise a right under state law like the MHMDA is denied, you may appeal that decision by contacting our Privacy Officer using the contact information in the Privacy Policy. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

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