Privacy Policy

1. Introduction

Pattern Health ("Company," "we," "us," or "our") operates the website located at patternhealthrx.com (the "Site") and provides telehealth assessment and care-path facilitation services (the "Services").

This Privacy Policy describes how we collect, use, disclose, and protect information about you when you use the Site or Services. Please read this policy carefully. By accessing the Site, you agree to the terms of this Privacy Policy.

[ATTORNEY: Add jurisdiction-specific introduction language, entity legal name, state of incorporation, and registered agent information as required.]

2. Information We Collect

a. Information You Provide Directly

• Name, email address, phone number
• Date of birth and state of residence
• Health history information submitted during intake
• Assessment and quiz responses
• Communications with our support team

[ATTORNEY: Confirm complete list of data fields collected. Specify whether any data constitutes Protected Health Information (PHI) under HIPAA and address accordingly. Confirm whether biometric or sensitive category data is collected.]

b. Information Collected Automatically

• IP address and approximate location
• Browser type, device type, and operating system
• Pages visited, time spent, and referral source
• Cookies and similar tracking technologies

[ATTORNEY: Confirm analytics tools in use (GA4, Meta Pixel, etc.) and address cookie consent requirements for applicable jurisdictions (GDPR, CCPA, etc.).]

c. Information from Third Parties

[ATTORNEY: Describe any third-party data sources (e.g., identity verification, pharmacy partners, referral partners). Confirm BAA requirements for any third parties handling PHI.]

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and improve the Site and Services
• Route your assessment responses to the appropriate care path
• Facilitate clinician review and eligibility determination
• Communicate with you regarding your assessment results and next steps
• Send administrative and transactional communications
• Comply with applicable legal and regulatory obligations
• Analyze usage to improve our assessment and care path experience

[ATTORNEY: Add lawful basis for processing under applicable law (CCPA, GDPR if applicable). Specify whether marketing communications require opt-in consent. Address use of health data for marketing purposes specifically.]

4. How We Share Your Information

We do not sell your personal information. We may share your information with:

• Licensed clinicians and healthcare providers for the purpose of eligibility review and care facilitation
• Pharmacy partners as applicable to your care path [CONFIRM]
• Service providers who assist in operating the Site and Services under confidentiality obligations
• Legal and regulatory authorities when required by law
• Business successors in the event of a merger, acquisition, or sale of assets

[ATTORNEY: Confirm complete list of third-party disclosures. Confirm BAA execution with all HIPAA business associates. Address "sale" of data under CCPA definition specifically — confirm no sharing that qualifies as a sale.]

5. Health Information and HIPAA

[ATTORNEY: This section requires careful drafting. Address: (1) whether the Company is a Covered Entity or Business Associate under HIPAA; (2) how PHI is handled, stored, and transmitted; (3) patient rights under HIPAA; (4) the relationship between this Privacy Policy and the separate HIPAA Notice of Privacy Practices; (5) any state-specific health privacy laws that apply (e.g., California Confidentiality of Medical Information Act).]

6. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Site, analyze usage, and support marketing activities. You may control cookie settings through your browser preferences.

[ATTORNEY: Confirm cookie consent mechanism required for applicable jurisdictions. List specific cookies and tracking pixels in use. Add opt-out mechanism language for CCPA "Do Not Sell or Share" if applicable.]

7. Data Retention

[ATTORNEY: Specify data retention periods for each category of data collected, particularly health information. Address medical record retention requirements under applicable state law. Specify deletion/anonymization procedures.]

8. Your Privacy Rights

Depending on your state of residence, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information
• Opt out of certain uses of your information
• Receive a copy of your information in a portable format

To exercise your rights, contact us at: privacy@patternhealthrx.com

[ATTORNEY: Tailor rights section to applicable law — CCPA (California), state telehealth privacy laws, HIPAA patient rights, etc. Add response timeline and verification process.]

9. Children's Privacy

The Site and Services are intended for adults 18 years of age and older. We do not knowingly collect personal information from individuals under 18. If you believe we have inadvertently collected such information, please contact us immediately.

[ATTORNEY: Confirm COPPA compliance language is sufficient for your operations.]

10. Security

[ATTORNEY: Describe actual security measures in place (encryption in transit, encryption at rest, access controls, etc.). Avoid over-promising. Include breach notification obligations under applicable law.]

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last updated" date at the top of this page and, where appropriate, by other means.

[ATTORNEY: Confirm notification method for material changes is sufficient under applicable law.]

12. Contact Us

If you have questions about this Privacy Policy, contact us at: