Privacy Policy

EFFECTIVE DATE: July 15, 2025

This privacy policy (“Policy”) describes how VIP Medical Group (“Company”, “we”, “us”, etc.) collects, uses, discloses and processes the personal data described in this Policy, as well as the rights and choices individuals have regarding such personal data. This Policy applies to the extent we process personal data on our own behalf, as a controller or business. This Policy does not apply to personal health information, which is addressed in our Notice of Privacy Practices policy. 

If you are a resident of California, please also refer to the “Additional Privacy Information for California Residents” section below, for information about the categories of personal information we collect and your rights under California privacy laws. 

1. Personal Data Collected 

As further described below, we collect personal data directly from individuals, as well as from third parties and automatically related to the use of our Services or other interactions with us.

Personal Data Collected Directly.  The personal data we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes: 

• • Communications and interactions.  When you visit our site or email, call, or otherwise communicate with us and with members of our team prior to becoming a patient, we collect and maintain a record of your contact details, communications and our responses. We also maintain records of communications and information that you post in chat sessions and in other areas of the Services, as well as on our social media channels.

Personal Data from Third Parties. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties. 

• • We may receive lead and prospect information from third parties, about prospective customers that may be interested in our Services.  We may also engage with third parties to enhance or update our customer information.

• • If you post reviews or information about us or engage with us on third party platforms or choose to link your Company account to or log in to our Services with a third-party account (e.g., Google), we may collect personal information about you from that third party platform or account. These third-party platforms and services control the information they collect and share about you.  For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies. 

Personal Data Collected Automatically.  We automatically collect personal data related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

• • Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Cookies and Tracking, below.
    
  • Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services, etc.
  • Location information. We may collect or derive location information about you, such as through your IP address.  Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.

2. Purposes of Collection and Processing

Generally, we collect, use and otherwise process the personal data we collect for the following purposes:

• Providing services and support. To provide and operate our Services,, provide troubleshooting and technical support, respond to your inquiries, process your payments, communicate with you, and for similar service and support purposes that are not related to your medical treatment.
  
• Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes.
• Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
• Marketing and advertising. For marketing and advertising purposes.  For example, to send you information about our Services, such as offers, promotions, newsletters and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
• Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
• Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Policy.
• Legal proceedings and obligations. To comply with the law and our legal obligations, to respond to legal process or related to legal proceedings.
• General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions. 

3. Disclosures of Personal Data

Generally, we disclose the personal data we collect in order to provide our Services, communicate with you, and for the purposes otherwise described in this Policy, including:

• Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes.
• Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop services and features, and for internal quality control and training purposes. 
• Marketing, advertising and campaign management. We may disclose certain information that includes personal data to third-party ad network providers, sponsors and/or traffic measurement services, who may use this data to improve and measure the effectiveness of our ads and those of third parties. For more information, see Advertising and Targeting, below.
• In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  We may also share certain personal data as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
• Compliance, governance and legal requirements. To comply with the legal and compliance obligations, to respond to legal process and related to legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.  We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions. In addition, we may disclose the names of sweepstakes and contest winners, in accordance with applicable law.   
• Security and protection of rights. To protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms or this Policy. 

We disclose and make available personal data, for the purposes described above, to third parties which generally include:

• Vendors and service providers. We may disclose personal data we collect to our service providers, processors and others who perform functions on our behalf. These may include, for example, IT or hosting service providers, help desk, etc.
• Our affiliates. We may disclose personal data we collect to our affiliates or subsidiaries, who will use and disclose this personal information in accordance with the principles of this Policy.
• Third party platforms, providers and networks.  We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests.  We may also make certain information (such as browsing information) available to third parties in support of our marketing, advertising and campaign management.
• Others as permitted by applicable law. We may also disclose personal data to third parties to the extent required by applicable law and legal obligations.  This may include regulators, government entities, and law enforcement as required by law or legal process.  

We disclose your personal data when we believe it is appropriate to do so, including to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms or this Policy, or as evidence in litigation.

Aggregated or Deidentified Information. We may share aggregated information derived from our Services and the personal data we collect, that does not identify or refer to any particular individual. Where we have committed to maintaining and using Personal Information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

4. Cookies and Tracking 

We and third-parties use cookies, pixels, java script, log files, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess, secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies within the Services.  

Cookies. Cookies are alphanumeric identifiers that we transfer to your device or browser. Some cookies make it easier to navigate our Services, while others allow us to track your activities in our Services, support the security and performance of the Services, or allow us to track activity and usage data within Service.  

Pixel tags. Pixel tags (sometimes called web beacons or clear GIFs) are tiny graphics with unique identifiers that are embedded within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party analytics and tools. We use third party tools, such as Google Analytics, to evaluate usage of our Services and to help us improve performance and user experiences. These third-party tools may use cookies and other tracking technologies, such as pixel tags, to perform their services. 

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising by following the instructions in the “Third-Party Ad Network” section. See below for information on global privacy controls. 

5. Advertising and Targeting

We work with third parties, such as ad networks, analytics and measurement services and others to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information within our Services (as well as on third-party sites and services), as well as IP address, unique IDs, and other identifiers.  We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.  

Ad Preferences. We make available several ways for you to manage your preferences regarding third-party advertising and cookies within our Services.  Most of these technologies are browser and/or device specific, which means that you need to set the preference for each browser and each device you use to access our Services; in addition, if you delete or block cookies, you may need to reapply these preferences.  Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us.   

• Industry ad choice programs. You can also control how participating companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant advertising to you. You can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) too. Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads on our Services. You may also continue to receive targeted ads on other websites from companies that do not participate in the above programs.
• Browser settings and controls. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse the Site, but some features may not function. 

Social Media. Our website and mobile application may include social media features. These features may collect electronic and other internet activity information, such as your IP address and which page you are visiting on our website or mobile application. These widgets may set a cookie or utilize other tracking technologies to accomplish this. Social media features and widgets are hosted by a third party and your interactions with those features are governed by the privacy policies of the companies that provide them.

Custom Lists and Matching. Unless you have opted out, we may share certain hashed customer list information (such as your name, email address and other contact information) with third parties so that we can better target ads and content to our users, and others with similar interests, within third party sites, platforms and services. You may opt out of being targeted by us in this manner, as set forth in  Your Privacy Choices.

6. Your Privacy Choices

You have certain choices regarding our processing of your personal data.  For example:

• Marketing communications. You can opt out of receiving marketing emails from us by using the unsubscribe link in the footer of each marketing email we send to you[, and you can opt out of receiving marketing and other texts from us by replying OPT OUT or STOP to any text we send to you. You can also change your preferences by logging in to your account and changing your marketing/communications preferences.
• Cookie preferences.  You can review or change your preferences for non-essential, third party cookies and tags on our website, other than those that are necessary to operation and functionality, by adjusting your cookie settings. These preferences are browser and devices specific.  So, you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies you may need to reapply these settings.  You may also adjust your advertising preferences as set forth in Advertising and Targeting.
• Privacy Settings.  You can adjust how others may view your profile and account information and interact with you on the Services, by logging into your account and adjusting your privacy settings.
• Updates. You can update some of the personal information we maintain about you, by logging into your account and updating your profile information or by contacting us as described below.

If you are a California resident, please review Additional Information for California Residents below, for specific information about your California Privacy Rights and how to exercise them.

For more information about our privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

7. Children/Minors

Our Services are not designed for children, and we do not knowingly collect personal data from children. If we discover that a child has provided us with personal data in violation of applicable law, we will delete such information from our systems. If you’re a parent or guardian and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Contact Us. 

8. Security

We have implemented safeguards that are intended to protect the personal data we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. 

There are also certain steps you can take to better protect against unauthorized access to your personal data.  For example, you should choose a strong password that is unique to the Services (and do not reuse passwords across multiple sites and services or share your password with others).

9. Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. 

10. Additional Privacy Information for California Residents  

a. Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act, as amended (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA such as personal health information or individually identifiable medical information.  

      i. Categories of Personal Information Under the CCPA (Last Updated: July 15, 2025)

While our processing of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected, used, shared and disclosed personal information (as defined by the CCPA) about California residents in the prior 12 months (from the Last Updated date above). 

Categories of Personal Information Collected and Disclosed. The table below identifies, generally, the categories of personal information we have collected about California residents, as well as the categories of third parties to whom we may disclose this personal information for a business or commercial purpose. 

Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources 

• Through our websites
• From third-party service providers, data brokers or business partners
• From third party sources including  
• Advertising networks
• Data analytics providers
• Social networks
• Internet service providers
• Operating systems and platforms
• Data brokers

Purposes for collecting and disclosing.  As described in more detail in Purposes of Collection and Processing, in general, we collect and otherwise process the above personal information for the following business or commercial purposes

• Services and support
• Analytics and improvement
• Customization and personalization
• Marketing and advertising
• Research and surveys
• Security and protection of rights
• Legal proceedings and obligations
• General business and operational support

As described in more detail in Section 3. Disclosures of Personal Data, generally, we disclose the personal data we collect in order to provide our Services to you, respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and for the purposes otherwise described in this Policy, including

• Services and support
• Analytics and improvement
• Marketing, advertising and campaign management
• Compliance, governance and legal requirements
• Security and protection of rights

Retention.  We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with legal obligations.

Sales and Sharing of Personal Information. The CCPA requires that we disclose how we ‘sell’ and ‘share’ personal information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value, and ‘share’ broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising.   As such, while we do not disclose personal information to third parties in exchange for monetary compensation, we may, pursuant to the CCPA, share: 

Internet and electronic network activity information, general location data, and unique identifiers (not including SSN or other government identifiers), which we may disclose or make available to advertising networks and third party ad companies, data analytics providers and social networks in support of our analytics and marketing, advertising and campaign management purposes, including to analyze use of the website, improve and measure our ad campaigns, and reach users with more relevant ads and content within the Services and on third party sites and services.

We do not, however, knowingly sell or share any personal information about minors under 16 years old. 

     ii. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

• Do-not-sell or share (opt-out): California residents may opt out of sales and sharing of their personal information by us, by submitting a request to compliance@vipmedicalgroup.com.  
• Right to limit use of sensitive personal information: the right to limit the use or disclosure of sensitive personal information to those uses authorized by the CCPA. We do not share sensitive personal information in this way. 
• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions. 
• Right to know: with respect to the personal information we have collected about them, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):

• • categories of personal information collected;
    
  • categories of sources of personal information;
  • categories of personal information about them we have disclosed for a business purpose, sold or shared; 
  • categories of third parties to whom we have sold, shared or disclosed for a business purpose their personal information; 
  • the business or commercial purposes for collecting, selling or sharing personal information; and
  • a copy of the specific pieces of personal information we have collected about them.

• Right to correct: the right to request that a business that maintains inaccurate personal information about the resident correct that personal information.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.  

Submitting CCPA Requests.  California residents may exercise their California privacy rights as set forth below.

Request to know (access), correct, delete and limit. California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us through one of the following methods:

• Submitting a request at compliance@vipmedicalgroup.com
• By phone at (646) 631-3516

Depending on your request, we may take steps to verify your request by (i) sending you an email confirmation link which you must click to confirm your request; and/or (ii) matching the information provided by you with the information we have in our records.  In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.  Authorized agents may initiate a request on behalf of another individual by contacting us as set out below; authorized agents will be required to provide proof of their authorization, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent depending on the nature of the request.    

Requests to Opt Out of Sales and Sharing.  California residents may submit a request to opt out of sales and sharing by:

• Submitting a request at compliance@vipmedicalgroup.com
• By phone at (646) 631-3516
• Turning on “Global Privacy Control” signals through your browser, which our website shall process as a request to opt out of sales and sharing for the relevant browser and device.

11. Contact Us
If you have questions about this Policy or our privacy practices, you may contact us at info@vipmedicalgroup.com and compliance@vipmedicalgroup.com.