Your privacy matters to us. Below you’ll find a clear explanation of what information we collect, how we use it, how we protect it, and how you can access or manage your data at any time. In short — we protect your data, and you control it.

Effective: January 2026 — replaces November 2023 version

This Website Privacy Policy (“Policy”) explains how Custom Health (“Custom Health,” “we,” “us,” or “our”) collects, uses, stores, and discloses personal information. By using our websites or digital services, you acknowledge that you have read and understand this Policy.

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Custom Health provides pharmacy services, technology-enabled medication management, connected health devices, clinical support, and related digital services. We are committed to protecting your privacy and handling personal information responsibly and in compliance with applicable privacy and data protection laws.

Quick Summary

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You may request access or deletion of personal information at any time via privacy@customhealth.com.

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1. Scope of this Policy

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This Privacy Policy applies to:

• customhealth.com and related web domains
• online forms, surveys, and registration pages
• marketing programs where you provide information

This Policy applies to personal information collected online and offline unless a separate privacy agreement or Notice of Privacy Practices (NOPP) applies. Where HIPAA applies to protected health information (PHI), the NOPP will govern that data.

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If you enroll in pharmacy, clinical monitoring, or device-enabled programs, additional HIPAA-required consents and notices will apply.

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2. Information We Collect

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a) Information you provide directly
We collect personal information you provide to us, such as name, contact information, messages, form submissions, company information, consent records, and survey responses.

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b) Automatically collected information
Technical data such as IP address, browser type, device identifiers, referral URLs, pages viewed, and session duration may be collected when you use our services.

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c) Cookies & tracking
We use cookies and analytics tools to support functionality, performance monitoring, and personalization. You may manage cookies in your browser settings; some features may not function without them.

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For more details on cookie types, usage, and browser control options, please see our Cookies & Tracking Notice.

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3. How We Use Information

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We may generally use Personal Information collected through the Site to provide access to the Website, comply with legal obligations, send you communications, and otherwise respond to your requests, comments, and questions, subject to applicable legal restrictions.

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4. How We Share Information

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We may share personal information collected through the Site as follows, subject to applicable legal restrictions:

• Subsidiaries and affiliates
• To the extent necessary for service providers that support our business and are contractually obligated to keep Personal Information confidential (examples of such third parties include website hosting providers, information hosting providers, customer support providers, communications vendors, and various other IT service providers)
• As necessary to comply with any applicable law, regulation, legal process, or government request
• Where we reasonably believe that such disclosure is necessary to protect your safety or the safety of others, to protect our rights or property, to address fraud, or to address a security or technical issue
• Other parties with your consent or direction. We do not sell your Personal Information to any third parties without your consent.

We do not share or sell personal information. If future activities are deemed “selling” or “sharing” under applicable law, we will update this Policy and provide opt-out options.

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5. Your Rights & Choices

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You may:

• Request access to personal information we hold
• Request corrections to inaccurate or incomplete data
• Request deletion of information, subject to legal obligations
• Opt out of marketing communications
• Manage cookies through browser settings
• Request a copy of your data where permitted by law

Additional rights may apply based on jurisdiction. See Section 12.

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6. Data Transfers

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Personal information may be stored or processed in the United States or Canada. We conduct a privacy impact analysis to ensure use appropriate safeguards, including contractual protections and access controls, are in place prior to any data transfer.

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7. Data Retention

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We retain personal information collected through our website only for as long as necessary to fulfill the purposes described in this Policy.

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The length of time we keep information depends on applicable legal requirements. When personal information is no longer needed, we take reasonable steps to delete it or de-identify it in accordance with our data management practices.

You may request deletion of certain personal information at any time by contacting privacy@customhealth.com.

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8. Security

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We use administrative, technical, and physical measures to protect personal information. No system is completely secure; we encourage users to protect account credentials and devices.

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9. Children’s Privacy

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This site is not intended for children under 13 (or under 18 without guardian oversight). If information is collected contrary to this requirement, we will delete it upon discovery.

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10. Changes to this Policy

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We may update this Policy periodically. The Effective Date will reflect the latest version.

Unless otherwise noted, all changes are effective when posted. By continuing to access or use the Site following notice of such changes, you acknowledge such changes and agree to be bound by their terms and conditions.

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11. Contact Us

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Email: privacy@customhealth.com

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Mailing addresses:

• 1631 Dickson Ave, Suite 900, Kelowna, BC V1Y 0B5, Canada
• 5115 Maryland Way, STE 13, Brentwood, TN 37027, USA

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12. Additional Jurisdictional Rights for Residents

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a) California (CCPA/CPRA)

California residents may request access to, correction of, or deletion of personal information, and may request details regarding data sharing practices. You will not be discriminated against for exercising privacy rights.

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To submit a request, email privacy@customhealth.com. Verification may be required.

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b) Canada (PIPEDA)

Canadian residents may request access, corrections, withdraw consent where applicable, or raise privacy concerns. Requests may be submitted to privacy@customhealth.com.

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If unresolved, individuals may contact the Office of the Privacy Commissioner of Canada or applicable provincial authority.