PRIVACY POLICY

At DENALIMANAGEMENTLLC dba TriArc Rx (“Company,” “we,” “us,” or “our”), we respect your privacy and are committed to protecting it. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.triarcrx.com,(the “Website”) or use our services. By accessing or using our services, you agree to the terms outlined in this Privacy Policy. If you do not agree, please do not use our services.

Introduction

This Privacy Policy describes how DENALIMANAGEMENTLLC (DBA TriArc Rx) (“TriArc Rx,” “Company,” “we,” “us,” or “our”) collects, uses, and protects information may collect from you or that you may provide when using the TriArc Rx website (the “Website”) or any related mobile applications (collectively the “Platform”). This Privacy Policy also details our practices for collecting, using, maintaining, protecting, and disclosing your information. Use of the Platform is governed by this Privacy Policy and our Terms of Service, which are incorporated by reference into this Privacy Policy. Any capitalized terms not defined in this Privacy Policy will have the meanings assigned to them in our Terms of Service. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to comply with this Privacy Policy and our Terms of Service. If you disagree with any aspect of this Privacy Policy, please refrain from using the Platform or providing any Personal Information. Your use of the Platform signifies your consent to the collection and use of your data as described herein, including sensitive health-related information where applicable.

This Privacy Policy does not apply to information collected by third parties, including through any external links or advertisements embedded within the Platform. However, third-party services integrated with our Platform may collect, use, or share your data, so we recommend reviewing their privacy policies to understand their practices.

We are committed to safeguarding your privacy. This Privacy Policy serves to inform you about the types of information we collect and the specific practices we follow to ensure the security and confidentiality of your personal information.

Information We Collect About You and How It’s Collected

1. Information About You and Your Health Care Treatment and Payment

We collect various types of information from and about users of our Platform, including:

• Personal Information: Information by which you may be personally identified, such as your name, mailing address, email address, phone number, account information, postal address, gender, occupation, billing details, eligibility, or any other information considered personally identifiable under applicable law (“Personal Information”).
• Health-Related Information: This includes clinical history, treatment records, and any communications exchanged through emails, texts, chats, or calls between you and us. All health-related information is handled in compliance with HIPAA and other applicable privacy regulations.
• Technical Information: Information about your Internet connection, the equipment you use to access our Platform, and usage details, such as device type and browser.
• General Information: This includes details about whether you are a current user, your product interests, location, demographics, or any other information related to your inquiries or requests.

1. Information We Share with Third Parties

We collect information from various sources, including:

• Directly from You: Information you provide to us when using the Platform.
• Automatically: As you navigate through our Platform, we may collect information such as your usage details, IP address, and information gathered via cookies and other tracking technologies.
• Third-Party Sources: We may receive information about you from third parties such as healthcare providers, pharmacies, or partners like Google Analytics, Meta, and payment processors. We may also collect information through your social media accounts if you use those accounts to sign in.

1. Information You Give to Us

The information we collect on or through our Platform includes:

• Browsing and App Use: Information collected as you browse our website or use our mobile apps, even if you don’t create an account.
• Account and Service Information: Information you provide when registering or signing into the Platform, using services, or communicating with us.
• Transaction Information: Details provided for processing treatment requests, payments, and customer service inquiries, including payment card information. We use encrypted connections to process payments, and we do not store full credit card details.
• Correspondence: Records of communications with us, such as emails or messages related to issues or services.
• Publicly Displayed Information: Information you provide for posting on the Platform, including any testimonials, which may include your first name and be visible publicly.

1. Your Search Queries on the Platform

As you interact with our Platform, we may use automatic tracking technologies to collect certain details about your usage:

• Visit Details: Information like traffic data, location, logs, language preferences, date and time of access, and resources accessed.
• Device Information: Data including your IP address, operating system, host domain, and browser type.
• Referring Websites: Details about where you came from, such as search engines or social media sites.

This automatic collection helps us improve our Platform and enhance your experience by:

• Estimating usage patterns.
• Storing information about your preferences.
• Speeding up your searches.
• Recognizing you on your return visits.

We may use cookies or similar technologies to collect and analyze data for better service delivery and personalization.

1. Information We Receive from Other Sources

We may receive information from other websites we operate, third-party partners, or third-party providers that help deliver services to you. This includes health-related data shared by medical providers and other sources such as lead generators for promotional purposes. We may combine information from these third-party sources with information we collect from you and use the combined data for the purposes described in Section III: How We Use Your Information.

By accessing or interacting with our Platform, you consent to the collection and use of your information as outlined in this section.

How We Share Your Information

We do not sell your personal information. However, we may share your information in certain circumstances. We share information with third-party service providers who assist us in operating our business, such as payment processors, IT service providers, and healthcare professionals involved in your care. We may also share information with regulatory authorities or law enforcement as required by law or to protect our rights, privacy, safety, or property. Additionally, if we are involved in a business transaction such as a merger or acquisition, your information may be transferred as part of that transaction.

Your Rights Under HIPAA

As a healthcare provider, TriArc Rx complies with the Health Insurance Portability and Accountability Act (HIPAA). Under HIPAA, you have specific rights regarding your health information, including:

• Accessing Your Records: You have the right to request a digital or physical copy of your medical records.
• Correcting Information: If your records are incomplete or inaccurate, you can ask us to correct them.
• Confidential Communication: You can request to be contacted through specific methods, such as email or an alternate mailing address.
• Restricting Disclosure: You can ask us to limit what we share, though we may decline if it affects your care.
• Receiving an Accounting of Disclosures: You can request a list of the entities with whom we’ve shared your health information over the past six years.
• Obtaining a Copy of This Notice: You may request a paper or electronic copy of this notice at any time.

HIPAA Compliance

TriArc Rx is committed to protecting your personal health information in accordance with the Health Insurance Portability and Accountability Act (HIPAA). We treat all Protected Health Information (PHI) with strict confidentiality and implement administrative, physical, and technical safeguards to ensure its privacy and security.

Business Associate Agreements (BAAs)

We may engage third-party service providers to support our platform. If these vendors handle PHI, we ensure they comply with HIPAA standards by entering into Business Associate Agreements (BAAs), requiring them to maintain appropriate safeguards.

Your Privacy Rights

Depending on your location, you may have specific rights under privacy laws, such as the California Consumer Privacy Act (CCPA) or the General Data Protection Regulation (GDPR), including the right to:

• Access and review the personal information we hold about you.
• Request corrections or deletions of your information.
• Opt out of data sharing or sale (if applicable).
• Receive a copy of your data in a portable format.

To exercise these rights, contact us at support@triarcrx.com

Cookies and Tracking Technologies

We may use cookies and similar technologies to improve user experience, analyze traffic, and deliver relevant content. You can control or disable cookies through your browser settings. By using our site, you consent to our use of cookies as described.

Data Security

We implement industry-standard safeguards to protect your information, including encryption, secure servers, role-based access controls, and periodic audits. While we strive to use commercially acceptable means to protect your information, no method of transmission over the internet is 100% secure.

Policy Updates

This Privacy Policy is effective as of 1/1/25. We may update this policy periodically, and any changes will be posted on this page. We encourage users to review it regularly to stay informed of how we are protecting your information.

Mobile Information Privacy

We respect your privacy and are committed to protecting your mobile information. We do not share, sell, or disclose your mobile phone number, SMS consent, or any related personal information with third parties or affiliates for marketing or promotional purposes. Mobile information will only be used for essential communications related to your services or as otherwise outlined in this Privacy Policy. Text messaging originator opt-in data and consent will not be shared with any third parties or affiliates for marketing or promotional purposes.

How We Use and Disclose Your Health Information

We use and disclose your health information for the following purposes:

• For Treatment: We share your health information with TriArc Rx providers and other healthcare professionals to ensure continuity of care. For example, a specialist may consult with your primary doctor regarding your condition.
• For Healthcare Operations: Your information is used to improve our services, manage operations, and communicate with you. For example, we may use patient feedback to enhance our programs.
• For Billing and Payment: We share relevant health information with insurers or third-party payers to process payments. For example, we submit necessary documentation to your health insurance provider to reimburse services.

Additionally, we may share your information for:

• Public Health and Safety: Reporting diseases, recalls, or adverse drug reactions.
• Research Purposes: Supporting research with strict safeguards to protect your privacy.
• Legal Compliance: Responding to subpoenas, court orders, or law enforcement requests.
• Emergency Situations: Assisting in disaster relief efforts or responding to serious safety concerns.

We will not use or share your information for marketing purposes, sell your data, or share psychotherapy notes without your explicit written permission.

Disclosure of Your Information

We may share your Personal Information, as described in this Privacy Policy, in the following ways:

• For Treatment, Payment, or Healthcare Operations: We may use or share your information for healthcare-related purposes, including treatment, payment processing, or other healthcare operations.
• With Authorized Parties: We may share your information with individuals or organizations you have authorized under this Privacy Policy or through any consent you have provided.
• With Service Providers: We may disclose your information to third-party service providers who assist us in operating and improving our Platform, such as those providing infrastructure support, email services, or security functions, in accordance with privacy laws and security protocols.
• With Medical Providers: We may share your information with healthcare providers (physicians, pharmacies, labs, etc.) who offer services to you or review your information as part of your care.
• With Our Affiliates and Employees: We may disclose your information to our affiliated entities and their employees who help us manage healthcare services or operational tasks related to your account.
• To Fulfill the Purpose You Provide It: For example, if you sign up for a particular service, we may need to share your data with the relevant parties to fulfill your request.
• To Third-Party Payment Processors: For payment processing, we may share your details with secure third-party processors, ensuring encrypted communication for transactions.
• To Comply with Legal Obligations: We may disclose your information to meet legal requirements or as needed to comply with applicable laws.
• For Marketing and Advertising: We may share your data with third parties that assist with marketing and advertising efforts related to our services.
• As Required for Legal or Safety Purposes: We may share your information if required to do so by law or to protect the rights and safety of our company or users, including for fraud prevention and identity verification.
• With De-Identified Information: We may use or share de-identified information for research, reporting, or other activities without revealing your personally identifiable information.

Data Retention

We retain personal and health-related information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Users may request deletion of their personal information by contacting us at support@triarcrx.com

Security of Your Data

We use commercially reasonable efforts to safeguard your Personal Information, including encryption, firewalls, and secure server protocols, to help prevent unauthorized access. However, no method of transmission over the internet or electronic storage is 100% secure, so we cannot guarantee absolute security

Children’s Privacy

Our services are not intended for individuals under the age of 13. We do not knowingly collect or solicit personal information from anyone under 13. If you believe a child has provided us with personal information, please contact us, and we will take steps to delete the information promptly.

California Privacy Rights

California residents have the right to request access to, delete, or opt-out of the sale of their Personal Information under the California Consumer Privacy Act (CCPA). If you wish to exercise any of these rights, please contact us using the details below.

Changes to This Privacy Policy

We may update this Privacy Policy periodically. When we do, we will notify you through the Platform or by email. Any changes will be effective once posted to the Platform.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data, please contact us at support@triarcrx.com