Our Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. Individuals who are between the ages of thirteen (13) and eighteen (18) (or such older age of majority) may use the Service for the sole purpose of obtaining a medical consultation for the treatment of bioidentical hormone replacement therapy through Thrivelab.com if a parent or legal guardian provides consent to such use in accordance with the requirements set forth in our Terms and Conditions and the Service. Services available through www.thrivelab.com are not available for individuals under eighteen (18) years of age or the applicable age of majority in their jurisdiction. The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal guardian if you are under age 13) may at any time request that we remove content or information about you that is posted on the Platform. Please submit any such request ("Request for Removal of Minor Information") to either of the following:

• By mailing: Thrivelab Co., Attn: Privacy Officer, 2719 S. El Camino Real, San Clemente CA 92672 with a subject line of "Removal of Minor Information. If you send by mail, please send by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking.
• By email privacy@thrivelab.com, with a subject line of "Removal of Minor Information"
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For each Request for Removal of Minor Information, please state "Removal of Minor Information" in the email or letter subject line, and clearly state the following in the body of the request:

• The nature of your request
• The identity of the content or information to be removed
• The location of the content or information on the Platform (e.g. by providing the URL)
• That the request is related to the "Removal of Minor Information"
• Your name, street address, city, state, zip code and email address, and whether you prefer to receive a response to your request by mail or email.
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We will not accept any Request for Removal of Minor Information via telephone or facsimile. Thrivelab is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Thrivalab to maintain the content or information; when Thrivelab maintains the content or information on behalf of your Providers (as defined in our Terms and Conditions) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Thrivalab anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Thrivelab' voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to be an admission that Thrivalab is subject to the Children's Online Privacy Protection Act, the Federal Trade Commission's Children's Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

When you set up an account with Thrivelab, you are creating a direct customer relationship with Thrivelab that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide information to Thrivelab, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, that we do not consider to be "protected health information" or "medical information".

However, in using certain components of the Service, you may also provide certain health or medical information that may be protected under applicable laws. Thrivelab is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, " HIPAA"). One or more of the Labs, Pharmacies or Medical Groups (as defined in our Terms and Conditions) may or may not be a "covered entity" or "business associate" under HIPAA, and Thrivalab may in some cases be a "business associate" of a Pharmacy or Medical Group. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Thrivalab, the Medical Groups, the Providers the Labs, or the Pharmacies. To the extent Thrivelab is deemed a "business associate" however, and solely in its role as a business associate, Thrivelab, may be subject to certain provisions of HIPAA with respect to "protected health information," as defined under HIPAA, that you provide to Thrivelab, the Medical Group or the Providers (" PHI"). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, "Protected Information" ), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.

The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes how they use and disclose Protected Information. By accessing or using any part of the Service, you are acknowledging receipt of the Notice of Privacy Practices from your Medical Group and Provider(s).

By accessing or using any part of the Service, you are agreeing that even if HIPAA does apply to Thrivelab, the Medical Groups, the Providers, the Labs or the Pharmacies, any information that you submit to Thrivalab that is not intended and used solely for the provision of diagnosis and treatment by the Medical Group and Providers, laboratory services by the Labs or prescription fulfillment by the Pharmacies, is not considered Protected Information, and will only be subject to our Privacy Policy and any applicable state laws that govern the privacy and security of such information. For purposes of clarity, information you provide to Thrivalab in order to register and set up an account on the Platform, including name, username, email address, shipping address and phone number, are not considered Protected Information.

We collect any information you provide when you use the Service, including, but not limited to:

• Personally identifying information such as your name and contact data such as your e-mail address, phone number, and billing and physical addresses
• Your login and password and other account (" Account") registration details
• Demographic data (such as your gender, date of birth and zip code)
• Computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes)
• Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram)
• Usage activity concerning your interactions with the Service and/or third-party websites, networks or applications accessed through the Service (e.g., viewing habits, viewing preferences, viewing history, number of clicks on a page or feature, amount of time spent on a page or feature, identify of third-party websites, networks, etc.)
• Billing, payment and shipping information
• Electronic signature
• Photographic or video images submitted for identification or non-diagnosis or treatment purposes
• Information about third parties that you refer to us (e.g., name, email, and/or other contact information, relationship)
• Statements or content (e.g., comments, videos, photographs, images) and information about such statements or content, which you submit or publish on or through the Service or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram)
• Any other information you provide when you contact or communicate with us
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If you use your mobile device to visit, access or use the Service, then additional categories of information that we collect may include

• Your name associated with your mobile device
• Your telephone number associated with your mobile device
• Your geolocation
• Your mobile device ID information
• With your express consent, your contacts and/or contact information (e.g., names, telephone numbers, physical addresses, email addresses, photos) stored on your mobile device
• With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps)
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We also collect certain medical information on behalf of the Medical Groups and your Providers, which may include, but is not limited to:

• Health and medical data you submit for diagnosis or treatment purposes, including information in any questionnaires or surveys you complete for these purposes
• Previous doctors or other healthcare providers you visited
• Date of visit
• Images or videos you share for diagnosis or treatment purposes
• Communications with Providers
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Thrivelab might collect personal and non-personal information directly from you when you visit, access or use the Service; when you register with or subscribe to the Service or any products or services available through the Service; when you "sign in," "log in," or the like to the Service; when you allow the Service to access, upload, download, import or export content found on or through, or to otherwise interact with, your computer or mobile device (or any other device you may use to visit, access or use the Service) or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever Thrivelab asks you for such information, such as, for example, when you process a payment through the Service, or when you answer an online survey or questionnaire. In addition, if you or a third party sends Thrivelab a comment, message or other communication (such as, by way of example only, email, letter, fax, phone call, or voice message) about you or your activities on or through the Site and/or the App, then Thrivelab may collect any personal or non-personal information provided therein or therewith.

In addition to the information we collect directly from you, we may also collect certain information from the Medical Group and/or Providers who provide treatment or other services to you in connection with our Service. This information may include, but is not limited to, diagnoses, treatment plans (including prescription details) and notes, and is accessible and visible through certain components of the Service.

We may also receive information from third parties that pay for your care or provide you with treatment, laboratory care or prescription medication, which may include, for example, your prescription history, insurance policy, insurance eligibility and coverage, and laboratory test results.

Finally, Thrivelab might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:

• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message. They may help store user preferences and activity and may allow a website to recognize a particular browser or device. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser's or device's preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device. Cookies can be set by the website owner (i.e., us), or they can be set by third parties (e.g., Facebook, Google, etc.) Cookies are used to help us speed up your future activities or to improve your experience by remembering the information that you have already provided to us. Third party cookies may also be used to enable analytics (e.g. Google Analytics) or advertising functionality (e.g., ad re-targeting on third-party websites) that enables more customized services and advertising by tracking your interaction with our Service and collecting information about how you use the Service.
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• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device. Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device. Flash cookies are not managed by the same browser settings that are used for regular cookies.
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• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer's, device's or browser's cookies may prevent some web beacons from tracking or recording certain information about your activities.
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• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user's interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user's computer or device from the website server, active only while the user is connected to the Site and/or the App, and deactivated or deleted when the user disconnects from the website.
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• Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website's or program's traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking. Examples of the analytic tools and services which Thrivalab might use include Google Analytics and Taplytics. Thrivalab may also use other third-party analytic tools and services.
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Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Platform might not function properly.

By visiting, accessing or using the Service, you acknowledge and agree in each instance that you are giving Thrivelab permission to monitor or otherwise track your activities on the Service, and that Thrivalab may use the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies. Notwithstanding the foregoing, Thrivalab does not permit third parties or third-party cookies to access to any communications you have with the Providers, or medical information that you submit to the Providers for diagnosis and treatment purposes.

We typically use or share your health information in the following ways:

Help manage the health care treatment you receive

• We can use your health information and share it with professionals who are treating you.
  Example: A doctor sends us information about your diagnosis and treatment plan so we can arrange additional services.
  

Run our organization

• We can use and disclose your information to run our organization and contact you when necessary.
  
• We are not allowed to use genetic information to decide whether we will give you coverage and the price of that coverage. This does not apply to long term care plans.
  Example: We use health information about you to develop better services for you.

Pay for your health services

• We can use and disclose your health information as we pay for your health services.
  Example: We share information about you with your dental plan to coordinate payment for your dental work.

Administer your plan

• We may disclose your health information to your health plan sponsor for plan administration.
  Example: Your company contracts with us to provide a health plan, and we provide your company with certain statistics to explain the premiums we charge.

We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.

Help with public health and safety issues

We can share health information about you for certain situations such as:

• Preventing disease
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting suspected abuse, neglect, or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety
  

Do research

• We can use or share your information for health research.
  

Comply with the law

• We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.
  

Respond to organ and tissue donation requests and work with a medical examiner or funeral director

• We can share health information about you with organ procurement organizations.
• We can share health information with a coroner, medical examiner, or funeral director when an individual dies.
  

Address workers’ compensation, law enforcement, and other government requests

We can use or share health information about you:

• For workers’ compensation claims
• For law enforcement purposes or with a law enforcement official
• With health oversight agencies for activities authorized by law
• For special government functions such as military, national security, and presidential protective services
  

Respond to lawsuits and legal actions

We can share health information about you in response to a court or administrative order, or in response to a subpoena.

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
  

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Thrivelab may retain your information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Service or Thrivelab. Thrivelab may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by Thrivelab or as required by law.

Similarly, the Medical Groups and Providers may retain your information for as long as they believe necessary; as long as necessary to comply with their respective legal obligations, resolve disputes and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Medical Groups and Providers. The Medical Groups and Providers may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by the Medical Groups or Providers or as required by law.

In connection with any transaction that you conduct through the Service (e.g., the purchase or sale of any products or services on or through the Service), you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting such information, you grant Thrivalab without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to third parties (e.g., payment processing companies, buyers on the Service, sellers on the Service) for the purpose of facilitating the transaction.

All credit card, debit card and other monetary transactions on or through the Service occur through an online payment processing application(s) accessible through the Service. This online payment processing application(s) is provided by Thrivalab' third-party online payment processing vendor, Stripe (" Stripe"). Additional information about Stripe, its privacy policy and its information security measures (collectively, the " Stripe Policies") should be available on the Stripe website located at https://stripe.com/us/privacy or by contacting Stipe directly. Reference is made to the Stripe Policies for informational purposes only and are in no way incorporated into or made a part of this Privacy Policy. Thrivalab' relationship with Stripe, if any, is merely contractual in nature, as Stripe nothing more than a third-party vendor to Thrivalab, and is in no way subject to Thrivalab' direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers or the like.

The Service may only be used within certain states within the United States as described in our Terms and Conditions. Accordingly, this Privacy Policy, and our collection, use, and disclosure of your information, is governed by U.S. law.

This site is being monitored by one or more third-party monitoring software(s), and may capture information about your visit that will help us improve the quality of our service. You may opt-out from the data that https://doublesmart.digital is collecting on your visit through a universal consumer options page located at https://doublesmart.digital/Unsub/unsub.html

This Privacy Policy does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third parties, including, without limitation, the Medical Group or its Providers, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Service may contain a link. These third parties may at times gather information from or about you. We do not control and are not responsible for the privacy practices of these third parties. We encourage you to review the Medical Group's Notice of Privacy Practices and the privacy policies of each website and application you visit and use.

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get a copy of health and claims records:

• You can ask to see or get a copy of your health and claims records and other health information we have about you. Ask us how to do this.
• We will provide a copy or a summary of your health and claims records, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
  

Ask us to correct health and claims records:

• You can ask us to correct your health and claims records if you think they are incorrect or incomplete. Ask us how to do this.
• We may say “no” to your request, but we’ll tell you why in writing within 60 days.
  

Request confidential communications:

• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
• We will consider all reasonable requests, and must say “yes” if you tell us you would be in danger if we do not.
  

Ask us to limit what we use or share:

• You can ask us not to use or share certain health information for treatment, payment, or our operations.
• We are not required to agree to your request, and we may say “no” if it would affect your care.
  

Get a list of those with whom we’ve shared information:

• You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
  

Get a copy of this privacy notice:

You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you:

• If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• We will make sure the person has this authority and can act for you before we take any action.
  

File a complaint if you feel your rights are violated:

• You can complain if you feel we have violated your rights by contacting us using the information on page 1.
• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
• We will not retaliate against you for filing a complaint.
  

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in payment for your care.
• Share information in a disaster relief situation.
  If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
  

In these cases we never share your information unless you give us written permission:

• Marketing purposes
• Sale of your information
  

The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Policy. As reflected in this table, we may share your personal information with a variety of outside entities.

If you are a California resident, you have the right to know what personal information we collect, use, disclose or sell about you under the CCPA. Additionally, you have the right to access and delete your personal information.

• How to request access to your personal information: You may request access to your personal information twice in a 12-month period. To do so, please email us at privacy@thrivelab.com with the subject heading "California Privacy Rights," or call 1-800-368-0038. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request. Note, we may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.
• How to request deletion of your personal information: You may request that we delete the personal information it has collected and/or maintained about you. To do so, please email us at privacy@thrivelab.com , or call 1-800-368-0038. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, maintain an electronic medical record for a Medical Group or Provider, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Verification: Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., login and password). If you are not a registered member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser or device ID).

Authorized Agents: Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your or your minor child's personal information. In order to designate an authorized agent to make a request on your behalf, you must provide written proof that you have consented to this designation unless the agent has power of attorney pursuant to California Probate Code sections 4000-4465. You must also verify your identity directly with us by providing a copy of your government issued identification.

Response Timing and Format: If you are a Thrivelab customer with an online account, we will deliver our written response to that account online or via email. If you are not a Thrivalab customer or do not have an online account, we will deliver our written response by mail or electronically, at your preference. The response will also explain the reasons we cannot comply with a request, if applicable. Please note, that if you are submitting a request regarding information you provided to a Medical Group, a Providers, or a Pharmacy, your request should be directed to that entity.

Anti-Discrimination Right: We will not discriminate against you for exercising any of your CCPA rights. But note that some of the functionality and features available to you may change or no longer be available to you upon deletion of your personal information or opt-out of sale of your personal information.

We do not sell your personal information for money, but we use cookies and similar technologies. Please see section on cookies in "How Information is Collected"; regarding our cookie usage. To opt out of cookies, click "CCPA - Do Not Sell My Information"

We do not and will not sell the personal information of minors under 16 years of age without affirmative authorization.

We strive to use reasonable physical, technical and administrative measures to protect information under our control. However, you must keep your Account password secure and your Account confidential, and you are responsible for any and all use of your Account. If you have reason to believe that the security of your Account has been compromised, please notify us immediately in accordance with the "Contacting Us" section below.

When using the Service, you may choose not to provide us with certain information, but this may limit the features you are able to use or may prevent you from using the Service all together. You may also choose to opt out of receiving certain communications (e.g., newsletters, promotions) by emailing us your preference. Please note that even if you opt out, we may still send you Service-related communications. We do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Thrivelab may supplement, amend, or otherwise modify this Privacy Policy at any time. Such supplements, amendments and other modifications will be posted on this or a similar page of the Service, and shall be deemed effective as of the "Last Updated" date; provided, however, that Thrivelab will notify you and/or require you to accept the updated Privacy Policy if the supplemented, amended or otherwise modified Privacy Policy implements material changes from Thrivelab' then-current Privacy Policy. It is your responsibility to carefully review this Privacy Policy each time you visit, access or use the Service.

If you have any questions about this Privacy Policy, please contact us by email at hello@thrivelab.com or by regular mail at:

Thrivelab Co
2719 S. El Camino Real
San Clemente, CA 92672

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