Privacy Policy

Avono is a digital health platform and administrative service provider. Independent Providers, pharmacies, laboratories, and other Clinical Partners may collect, use, maintain, or disclose your health information under their own privacy notices, professional duties, and legal obligations. When Avono receives, creates, maintains, or transmits Protected Health Information on behalf of a HIPAA-covered entity, Avono may do so as a business associate or service provider under applicable agreements and law.

This Privacy Policy does not replace any Notice of Privacy Practices, authorization, consent, or privacy notice provided by a Provider, pharmacy, laboratory, or other Clinical Partner. If there is a conflict between this Privacy Policy and a HIPAA Notice of Privacy Practices regarding Protected Health Information, the Notice of Privacy Practices and applicable law will control for that Protected Health Information.

Depending on how you interact with the Services, we may collect the following categories of information:

• Identifiers and contact information. Name, email address, phone number, mailing address, billing address, date of birth, account ID, government ID information where required for identity verification, and similar identifiers.
• Account and authentication information. Username, password or authentication credentials, account preferences, security questions, login history, consent records, and account activity.
• Health and wellness information. Medical history, current conditions, symptoms, treatment goals, medication history, allergies, adverse reactions, pharmacy information, lab information, photos or uploads, intake responses, provider messages, prescription information, side-effect reports, lifestyle information, height, weight, sex, gender-related information where clinically relevant, and other information you choose to provide.
• Commercial and transaction information. Products or services requested, subscriptions, purchases, renewals, cancellations, coupon codes, referral or ambassador codes, billing status, shipping status, and customer support history.
• Payment information. Payment card or bank details may be processed by third-party payment processors. Avono generally does not store full payment card numbers.
• Communications. Emails, text messages, calls, chats, portal messages, support requests, survey responses, consent records, and other communications with Avono or through the Services.
• Device, internet, and usage information. IP address, device identifiers, browser type, operating system, referring pages, pages viewed, session activity, approximate location derived from IP address, cookie identifiers, log files, and similar technical information.
• Marketing and preference information. Marketing preferences, ad interactions, referral source, survey information, and information about how you respond to communications.
• Inferences. Preferences, likely interests, service eligibility indicators, risk flags, fraud indicators, or similar information derived from other information, where permitted by law.

We may collect information directly from you, automatically from your devices, from Providers and Clinical Partners, from pharmacies and laboratories, from payment processors, from identity verification vendors, from referral or ambassador partners, from marketing and analytics providers, from public sources, and from other third parties you authorize or that are permitted by law to provide information to us.

We may use information for the following purposes:

• Provide, operate, maintain, personalize, and improve the Services.
• Create and manage accounts, process intake forms, coordinate Provider review, and facilitate communications among you, Providers, pharmacies, laboratories, and other Clinical Partners.
• Verify identity, age, location, eligibility, payment status, and compliance with service requirements.
• Process payments, subscriptions, renewals, cancellations, refunds, disputes, chargebacks, taxes, shipping, and customer support.
• Coordinate prescriptions, pharmacy fulfillment, lab testing, shipping, medication refills, follow-up requests, and related administrative services.
• Send transactional, administrative, support, health-related, security, policy, and service communications.
• Send marketing communications where permitted by law and your preferences.
• Analyze usage, monitor performance, debug errors, improve user experience, test features, and develop new services.
• Detect, investigate, prevent, and respond to fraud, abuse, unauthorized access, security incidents, misuse, illegal activity, and policy violations.
• Comply with law, subpoenas, court orders, government requests, professional obligations, recordkeeping duties, and contractual obligations.
• Enforce our agreements, protect legal rights, defend claims, and complete corporate transactions.

We may disclose information to the following categories of recipients where appropriate and permitted by law:

• Providers and Clinical Partners. Independent licensed clinicians, professional entities, pharmacies, laboratories, and care coordination partners involved in evaluating eligibility, providing care, dispensing medications, lab testing, or related services.
• Service providers and vendors. Companies that provide hosting, cloud infrastructure, customer support, identity verification, payment processing, analytics, communications, email, SMS, shipping, security, auditing, compliance, and other operational services.
• Payment and financing partners. Payment processors, banks, card networks, fraud-prevention vendors, and collections or dispute-resolution providers.
• Marketing, analytics, and advertising partners. Partners that help us understand non-portal website activity, measure campaigns, or market Avono services, subject to applicable law and user choices. We do not knowingly disclose Protected Health Information to advertising platforms for targeted advertising unless legally permitted and authorized where required.
• Referral and ambassador partners. Where you use a referral, coupon, or ambassador code, we may disclose limited information necessary to administer the program, such as attribution and commission eligibility, subject to applicable law.
• Legal, regulatory, safety, and enforcement recipients. Courts, regulators, law enforcement, government authorities, legal counsel, insurers, auditors, compliance advisors, and others where disclosure is necessary or appropriate to comply with law, protect rights, prevent harm, or enforce agreements.
• Corporate transaction parties. Actual or potential buyers, investors, lenders, successors, affiliates, merger partners, acquirers, or advisors in connection with financing, diligence, merger, acquisition, restructuring, bankruptcy, or sale of assets.
• With your direction or consent. Other persons or entities when you request, authorize, or consent to disclosure.

We may use cookies, pixels, tags, SDKs, local storage, session replay tools, analytics tools, and similar technologies to operate the Services, remember preferences, secure accounts, measure performance, improve the website, and market our services. Some technologies are necessary for the Services to function; others may be optional depending on your browser, device, settings, and applicable law.

We aim to avoid using advertising or analytics technologies in a manner that discloses Protected Health Information to third-party advertising platforms without appropriate authorization or legal basis. Users should understand that browser settings, cookie choices, ad blockers, and privacy controls may not fully prevent all tracking or technical collection.

Avono does not sell Protected Health Information. Avono does not sell consumer health data where prohibited by law or without required authorization. Certain privacy laws may define "sale" or "sharing" broadly to include some advertising, analytics, or cross-context behavioral advertising activities involving personal information. Where required, we will provide applicable opt-out rights and honor valid choices.

Some state laws, including consumer health privacy laws, may apply to health-related information that is not Protected Health Information under HIPAA. To the extent such laws apply, "consumer health data" may include personal information that is linked or reasonably linkable to you and that identifies or could be used to infer your past, present, or future physical or mental health status, health condition, treatment, medication, care, body function, vital signs, reproductive or sexual health, gender-affirming care, precise location information that could indicate an attempt to receive health services, or similar health-related information.

We may collect consumer health data only as reasonably necessary to provide requested services, support Provider review, facilitate pharmacy or lab services, operate and improve the Services, communicate with you, comply with law, protect safety and security, and for other purposes described in this Privacy Policy or disclosed at collection. We may disclose consumer health data to Providers, Clinical Partners, pharmacies, laboratories, service providers, and others as described in this Privacy Policy. We will obtain consent or authorization where required by applicable consumer health privacy laws.

Depending on your state of residence and applicable law, you may have the right to request access to personal information, correction, deletion, portability, restriction, limitation of sensitive data use, opt-out of sale, opt-out of sharing for cross-context behavioral advertising, opt-out of targeted advertising, opt-out of certain profiling, withdraw consent, appeal a privacy decision, or receive information about third parties to whom information has been disclosed. To submit a request, contact compliance@avono.io.

We may verify your identity before fulfilling a request. We may deny or limit requests where permitted by law, including where information is needed to provide services, complete transactions, comply with legal or medical record obligations, protect security, prevent fraud, exercise legal rights, or preserve records. We will not unlawfully discriminate against you for exercising privacy rights.

If the California Consumer Privacy Act, as amended, applies to Avono and to your information, California residents may have rights to know, access, correct, delete, obtain a copy of, opt out of sale or sharing of, and limit the use and disclosure of sensitive personal information. Avono may collect the categories of personal information described in Section 2 of this Privacy Policy for the purposes described in Section 4 and may disclose them as described in Section 5.

Avono does not knowingly sell or share personal information of individuals under 18. Avono does not use sensitive personal information to infer characteristics except as permitted by law, to provide requested services, or as otherwise disclosed and permitted. To exercise rights, contact Avono at the email below. Authorized agents may submit requests where permitted by law, but Avono may require verification and proof of authority.

Where consumer health privacy laws apply, you may have rights to access, confirm, delete, withdraw consent, obtain a list of third parties or affiliates with whom consumer health data has been shared, and appeal a denial of your request. Avono will not sell consumer health data or use it for targeted advertising where prohibited without legally required authorization or consent. Submit requests to compliance@avono.io.

Avono does not use geofencing around health care facilities to identify, track, collect consumer health data from, or send health-related targeted advertising to consumers where prohibited by law.

You may opt out of marketing emails by using the unsubscribe link or contacting us. You may opt out of marketing text messages by replying STOP or following provided instructions. Even if you opt out of marketing, we may still send transactional, administrative, security, account, payment, care coordination, policy, or legally required communications.

We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide services, support Provider and pharmacy operations, comply with medical record and legal obligations, resolve disputes, collect fees, enforce agreements, maintain security, prevent fraud, and preserve business records. Retention periods vary by information type, service, legal requirement, and operational need.

We use reasonable administrative, technical, and physical safeguards designed to protect information. However, no website, platform, system, network, communication method, or storage technology is completely secure. You use the Services at your own risk and are responsible for securing your devices, accounts, passwords, email, phone, and network access.

We may create, use, disclose, and retain deidentified, aggregated, or anonymized information for analytics, research, product improvement, business, compliance, marketing, benchmarking, and other lawful purposes. We will not attempt to reidentify information that we maintain as deidentified except as permitted by law, such as to test whether deidentification is effective.

The Services are intended for adults age 18 or older. We do not knowingly collect personal information from children under 18. If you believe a child has provided information to us, contact us so we can evaluate and take appropriate action.

The Services may link to or integrate with third-party websites, portals, payment processors, pharmacies, laboratories, shipping carriers, identity verification tools, or other services. We are not responsible for the privacy, security, content, practices, or availability of third-party services. Review their terms and privacy notices before using them.

We may update this Privacy Policy from time to time. The updated version will be indicated by a revised "Last Updated" date or other notice. Continued use of the Services after an update means you acknowledge the updated Privacy Policy, subject to applicable law.

For privacy questions, requests, appeals, or complaints, contact Avono at compliance@avono.io.

Avono Health

compliance@avono.io

avonohealth.com