Privacy Policy
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MEDBREVIA PRIVACY POLICY Version 11.0 — Effective Date: December 15, 2025 1. INTRODUCTION This Privacy Policy ("Policy") describes how MedBrevia LLC ("MedBrevia," "Company," "we," "us," or "our") collects, uses, discloses, and protects information in connection with our application, website, and services (collectively, the "Service"). This Policy applies to all users who access the Service through any means. By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with any part of this Policy, please do not access or use the Service. 2. IMPORTANT NOTICE FOR INTERNATIONAL USERS THE SERVICE IS OPERATED FROM THE UNITED STATES AND IS INTENDED FOR USERS LOCATED IN THE UNITED STATES. IF YOU ARE LOCATED IN THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, UNITED KINGDOM, SWITZERLAND, OR ANY OTHER JURISDICTION WITH DATA PROTECTION LAWS MORE RESTRICTIVE THAN THOSE OF THE UNITED STATES, PLEASE DO NOT USE THIS SERVICE. MedBrevia and its technical infrastructure are located in the United States. By using the Service, your information will be transferred to, stored, and processed in the United States, which may not provide the same level of data protection as your home jurisdiction. The Service is not designed to comply with the General Data Protection Regulation (GDPR), UK GDPR, or similar international data protection frameworks. We do not appoint data protection officers or representatives in the EU/EEA. If you choose to use the Service from outside the United States despite this notice, you do so at your own risk and consent to the transfer and processing of your information in the United States in accordance with this Policy and U.S. law. 3. PROTECTED HEALTH INFORMATION AND AI TRAINING 3.1 Our Commitment MEDBREVIA DOES NOT TRAIN AI MODELS ON PROTECTED HEALTH INFORMATION (PHI). We understand the sensitivity of health-related information. While our Service may process queries containing health-related content to provide responses, we maintain strict policies and technical safeguards to ensure that any information that could constitute PHI is not used to train, improve, or develop AI models. User queries containing sensitive health information are processed solely to generate responses and are not retained for model training purposes. 3.2 User Responsibilities We strongly advise users to avoid inputting identifiable patient information or PHI into the Service, to de-identify any health-related information before submitting queries, and to consult with appropriate privacy officers if you have questions about appropriate use. 3.3 HIPAA Clarification MedBrevia is not designed or intended to serve as a Business Associate under HIPAA. We do not enter into Business Associate Agreements (BAAs) and the Service is not intended for the storage, processing, or transmission of PHI. If you are a Covered Entity or Business Associate under HIPAA, you are solely responsible for ensuring your use of the Service complies with HIPAA requirements. 4. INFORMATION COLLECTED 4.1 Information You Provide When you use the Service, you may provide us with certain information such as your name, email address, profession, specialty, and other registration information. You may also provide payment information when making purchases and submit queries and content through the Service. 4.2 Automatically Collected Information When you access or use the Service, we automatically collect certain information including usage data (such as features used, actions taken, content viewed, and time spent), device and technical information (such as device type, operating system, browser type, IP address, and advertising identifiers), and general geographic location derived from your IP address. 4.3 Information from Third Parties We may obtain additional information about you from third-party sources to verify your registration information, enhance our records, or personalize the Service. 5. COOKIES AND TRACKING TECHNOLOGIES We use cookies, pixels, web beacons, and similar tracking technologies to collect information about your interactions with the Service. These technologies help us analyze usage patterns, remember your preferences, authenticate sessions, deliver relevant content and advertising, and improve the Service. You can manage cookie preferences through our cookie preference controls and your browser or device settings, though some features may not function properly if cookies are disabled. We also use Google Analytics 4 and Google Ads. We implement Google Consent Mode, which means that when you reject non-essential cookies, Google may still receive limited, cookieless signals for aggregated measurement and conversion modeling. Your choices control whether analytics/advertising cookies and personalization are used. 6. USER PROFILES AND PERSONALIZATION 6.1 Profile Creation We may associate information collected about your use of the Service with your registration information and other data we have about you to create a user profile ("User Profile"). This profile may be updated from time to time based on your continued use of the Service and information obtained from third-party sources. 6.2 Personalization of Content We use your User Profile to personalize the Service, including the content, information, and communications you receive. Personalization is based on factors including your profession, specialty, interests (stated or inferred), usage patterns, content engagement, and geographic location. 7. SPONSORED CONTENT AND ADVERTISING 7.1 Delivery of Sponsored Content The Service may include sponsored content, advertisements, and promotional materials from third-party sponsors, which may include pharmaceutical companies, medical device manufacturers, healthcare organizations, and other commercial entities. By using the Service, you consent to receive such sponsored content. 7.2 Targeted Advertising We may use information from your User Profile to deliver targeted advertisements and sponsored content that we believe may be relevant to you based on your profession, specialty, interests, and usage patterns. This targeted content may appear within the Service, in email communications, and through other channels. 7.3 Information Shared with Sponsors When you view or interact with sponsored content or advertisements, we may provide certain information from your User Profile (such as your profession, specialty, and engagement details) to the applicable sponsor or its agents. We do not share your direct contact information (email address, phone number, or postal address) with sponsors without your separate consent. Sponsors may use their own tracking technologies in advertisements served through the Service. 7.4 Identification of Sponsored Content All sponsored content and advertisements will be identified by labels such as "Sponsored," "Advertisement," "Promoted," or similar designations. 8. DATA LICENSING AND THIRD-PARTY SHARING 8.1 Aggregated and De-Identified Data We may create aggregated, de-identified, or anonymized data from the information we collect. Such data cannot reasonably be used to identify you personally. We may use, license, sell, or otherwise disclose aggregated and de-identified data for any lawful purpose, including to third parties for commercial purposes, research, analytics, and product development. 8.2 Licensed Data Recipients We may license or sell certain non-personal data, usage data, and aggregated information to authorized third parties, including data analytics companies, research organizations, advertising networks, and commercial partners. This data may be used by recipients for their own business purposes, including market analysis, product development, advertising optimization, and research initiatives. 8.3 User Profile Data Subject to applicable law, we may provide portions of User Profile data (excluding direct contact information) to third parties, including our advertising customers and business partners, for purposes including marketing, audience targeting, and analytics. These third parties may use such information for their own business purposes. 8.4 Restrictions on Data Use by Recipients Third parties who receive data from us are prohibited from using such data for unlawful purposes and are required to implement appropriate security measures. However, once data is provided to third parties, their use of such data is governed by their own privacy policies and practices. 9. HOW WE USE YOUR INFORMATION We use information collected about you for the following purposes: • To provide, maintain, and improve the Service • To process your queries and generate responses • To create and manage your account and process payments • To personalize content, advertising, and communications • To deliver sponsored content and targeted advertising • To communicate with you about the Service and promotional offers • To protect against fraud, abuse, and unauthorized access • To comply with legal obligations and enforce our policies • To develop new features and analyze usage patterns • To license or sell data as described in this Policy 10. OTHER INFORMATION SHARING In addition to the sharing described above, we may share your information in the following circumstances: 10.1 Service Providers We work with third-party service providers to help us operate the Service, including providers of cloud hosting, payment processing, analytics, authentication, AI processing, and content delivery. 10.2 Legal Requirements We may disclose your information if required by law or in response to valid requests by public authorities, to comply with legal obligations, to protect our rights or property, to prevent wrongdoing, or to protect personal safety. 10.3 Business Transfers If MedBrevia is involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. 10.4 Affiliates We may share your information with any member of our corporate group, including subsidiaries and affiliates, for purposes consistent with this Policy. 10.5 With Your Consent We may share your information for other purposes with your consent. 11. DATA SECURITY We implement appropriate technical and organizational security measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials. 12. DATA RETENTION We retain your information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. We may retain de-identified or aggregated data indefinitely. When personal information is no longer needed, we will securely delete or anonymize it. 13. YOUR CHOICES AND PRIVACY RIGHTS 13.1 Account Information You may update your registration information at any time through your account settings or by contacting us. 13.2 Marketing Communications You may opt out of promotional email communications by clicking the "unsubscribe" link in any promotional email. Note that you may continue to receive service-related communications. 13.3 Cookies and Tracking You can manage cookie preferences through your browser settings. You may also control interest-based advertising through your mobile device settings. 13.4 California Residents If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including: • The right to know what personal information we collect, use, and disclose • The right to delete your personal information • The right to correct inaccurate personal information • The right to opt out of the "sale" or "sharing" of your personal information • The right to limit use of sensitive personal information 13.4.1 "Do Not Sell or Share My Personal Information" Under California law, "sale" means disclosing personal information to a third party for monetary or other valuable consideration. "Sharing" means disclosing personal information for cross-context behavioral advertising purposes. As described in Sections 7 and 8 of this Policy, we may disclose certain User Profile information (such as profession, specialty, and engagement data) to advertising partners and sponsors for targeted advertising purposes. This may constitute a "sale" or "sharing" under California law. To opt out of the sale or sharing of your personal information: • Visit: medbrevia.com/privacy and click "Your Privacy Choices" • Use the opt-out toggle in your account privacy settings • Email us at product@medbrevia.com with the subject line "Do Not Sell or Share" 13.4.2 Global Privacy Control (GPC) and Opt-Out Preference Signals We honor opt-out preference signals, including the Global Privacy Control (GPC), where required by applicable law. When we detect a GPC signal from your browser or device, we will treat it as a valid request to opt out of the "sale" or "sharing" of personal information associated with that browser or device. Please note that GPC signals apply to the specific browser or device from which the signal is sent. If you use multiple browsers or devices, you may need to enable GPC on each one, or sign in to your account to apply your opt-out preference across all your sessions. We will not discriminate against you for exercising your privacy rights. You will not receive different pricing, quality of service, or access to features based on your privacy choices. 13.4.3 Submitting Requests, Verification, and Appeals How to Submit Requests: To exercise your rights to know, delete, or correct your personal information, email us at product@medbrevia.com or visit medbrevia.com/privacy. We will respond to verifiable requests within 45 days. Verification: To protect your privacy, we will verify your identity before processing your request. We will match the information you provide with information we already have on file. We will not collect more information than necessary for verification. Authorized Agents: You may designate an authorized agent to submit requests on your behalf. Authorized agents must provide written authorization signed by you, and we may require you to verify your identity directly with us. Appeals: If we deny your request, you may appeal by emailing product@medbrevia.com with the subject line "Privacy Request Appeal." We will respond to appeals within 45 days. 13.5 Other U.S. State Privacy Laws Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy legislation may have similar rights, including: • The right to access and obtain a copy of your personal data • The right to delete your personal data • The right to correct inaccurate personal data • The right to opt out of targeted advertising • The right to opt out of the sale of personal data (where applicable) • The right to appeal a denial of your request To exercise these rights, visit medbrevia.com/privacy or email us at product@medbrevia.com. We will respond within the timeframes required by applicable law (generally 45 days). If we deny your request, you may appeal by emailing product@medbrevia.com with the subject line "Privacy Request Appeal." 14. QUERY DATA We collect information related to your queries and interactions with our AI assistant. You have the ability to view your stored query history, delete individual queries or your entire history, and request a copy of your data. Your queries may be processed by third-party AI providers to generate responses. 15. CHILDREN'S PRIVACY The Service is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information. 16. CHANGES TO THIS POLICY We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Policy and updating the Effective Date. Your continued use of the Service after the effective date constitutes acceptance of the changes. 17. CONTACT US If you have questions about this Privacy Policy, please contact us at: MedBrevia LLC 2810 N Church St PMB 643901 Wilmington, Delaware 19802-4447 Email: product@medbrevia.com — END OF PRIVACY POLICY —