Privacy Policy

SPHERE HEALTH operates a direct-to-consumer women's telehealth platform offering virtual clinical consultations, lab-based screening, and ongoing care across five clinical segments: PCOS, weight/metabolic health, endometriosis, and perimenopause/HRT.

SPHERE HEALTH is not a medical group or a health care provider. We do not provide medical advice, diagnosis, or treatment. Instead, we provide our users with the ability to obtain a telemedicine consultation provided by independent medical practitioners and pharmacists, including, but not limited to, M&D Integrations, Inc. d/b/a MD Integrations ("MD Integrations"), and all members of MD Integrations' affiliated covered entities (collectively, "Medical Group"), which are independent medical groups with a network of United States based health care providers (each, a "Provider"). Medical Group (or your own medical provider, if you do not use a Medical Group Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not SPHERE HEALTH. SPHERE HEALTH does not control or manage any aspect of your clinical relationship with these Providers.

It is helpful to start by explaining some of our key terms and definitions used in this Privacy Notice.

When does our Privacy Notice apply?

This Privacy Notice describes the types of information we may collect from you when:

• You visit or use our Platform, including our Website;
• We communicate in e-mail, text message, and other electronic messages between you and us; and
• We communicate in person, such as on the phone or through a telehealth visit.

When does our Privacy Notice not apply?

This Privacy Notice does not apply to information collected by any other website operated either by us or by a third party, unless the website is listed above or links to this Privacy Notice. It also does not apply to any website to which we may provide a link or that is accessible from our Platform.

This Privacy Notice does not apply to information collected from users who log-in to the password-protected and secure portions of our Platform ("Secure Platform"). The Secure Platform allows users who obtain the Services ("Customers") to perform certain functions or obtain the Services (such as telehealth visits from Medical Group or Providers). All information collected and stored by us or added by Customers into the Secure Platform is considered health information and/or medical information and is governed by applicable state and federal laws that apply to that information. How we use and disclose such information is in accordance with the applicable Notice of Privacy Practices provided to you by the Medical Group. We will not use or disclose information collected from the Secure Platform or received from Medical Group or your Provider for advertising, marketing, or other purposes except as otherwise permitted by applicable law.

Our Privacy Notice and Terms and Conditions

This Privacy Notice is incorporated into our Terms and Conditions, which also apply when you use our Platform.

What is Personal Information?

Personal Information is information from and about you that may be able to personally identify you. We treat any information that may identify you as Personal Information. For example, your name and e-mail address are Personal Information.

What types of Personal Information do we collect?

We may collect and use the following Personal Information:

Health Information

Some Personal Information we collect may constitute protected health information. As set forth above, your Provider will provide you with a Notice of Privacy Practices describing their collection and use of your health information, not SPHERE HEALTH. We will only collect and use protected health information for the purposes of providing the Services or as otherwise permitted by law. We may combine your protected health information with Personal Information that we have either obtained from you or through a third-party, such as your Provider or other health care providers. Protected health information will not be used for any other purpose without your consent or as otherwise permitted by law.

How do we collect your Personal Information?

We collect most of this Personal Information directly from you. For example, when we speak to you by phone, text message, and e-mail. Additionally, we will collect information from you when you visit our Website and fill out forms or purchase our Services.

We may also collect Personal Information in the following ways:

• When you make payments through the Platform. We do not collect or store financial account information, though we may receive transaction identifiers and summary information that does not include credit card or bank account numbers. Our payment processor's privacy policy may be found at: https://www.jpmorgan.com/privacy.
• When you contact us. When you contact SPHERE HEALTH directly, such as when you contact our Customer Support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.
• From third parties. We may collect Personal Information from trusted third parties such as MD Integrations, telehealth service providers that assist with connecting our members with licensed healthcare professionals, ThePharmacyHub, Strive Pharmacy, Belmar Pharma Solutions, our partner pharmacy service, Junction, our partner for laboratory services, or other service providers as necessary to deliver our Services effectively. We may also collect Personal Information from your attorney if they contact us on your behalf about our Services. If we do, we always collect that information with the limitation that we only collect the information to perform the Services.

We will also collect information automatically as you navigate through our Platform. We use the following technologies to automatically collect data:

• Cookies. We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Platform or Services through your computer or mobile device. A "cookie" is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Website and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Platform and/or the Services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Platform or the Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
  BY CONTINUING TO ALLOW COOKIES (SEE CHOICES ABOUT HOW WE USE AND SHARE YOUR INFORMATION), YOU HEREBY CONSENT TO OUR RECORDING AND DISCLOSURE TO THIRD-PARTY COOKIE PROVIDERS OF YOUR USE OF THE PLATFORM OR OTHER COMMUNICATIONS YOU MAY HAVE WITH OUR PLATFORM.
• Facebook (Meta) Pixel and Instagram. We use Facebook Pixel and Instagram, a web analytics and advertising service provided by Facebook Inc. ("Facebook"), on our Platform. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel and Instagram is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others' advertising purposes, in accordance with Facebook's Data Policy, which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to collect certain information relating to your use of our Platform. Google Analytics uses cookies to help our Platform analyze how users use our Website. You can find out more about how Google uses data when you visit our Platform by visiting "How Google uses data when you use our partners' sites or apps" (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• Google Ads (AdWords). Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout– for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
• LinkedIn. For more information, we encourage you to review the LinkedIn Privacy Policy, located here: https://www.linkedin.com/legal/privacy-policy.
• TikTok. For more information, we encourage you to review the TikTok Privacy Policy, located here: https://www.tiktok.com/legal/page/us/privacy-policy/en.
• Other third-party tools. We use other third-party tools which allow us to track the performance of our Platform. These tools provide us with information about errors, app and website performance, and other technical details we may use to improve our Platform or the Services.

How do we use your Personal Information?

We may use your Personal Information for the following purposes:

• To fulfill or meet the reason you provided the information.
• In the event of a merger, divestiture, restructuring, etc.
• To respond to law enforcement requests.
• To defend against claims or to protect our rights, employees, or property.
• To enforce our Terms and Conditions, billing, or other contract-related activities.
• To provide support, personalize, or develop the Services.
• To maintain, customize, and secure your account (including notices about subscriptions, expiration, and renewals, if applicable).
• To process your requests, purchases, transactions, and payments and/or to prevent transactional fraud.
• To send newsletters and other similar communications that do not specifically advertise our own goods and services.
• To provide you with support and to respond to your inquiries (including to investigate and address concerns and monitor/improve responses).
• For behavioral/targeted advertising, including auditing related to behavioral advertising (such as counting advertising impressions, verifying advertising impressions, etc.).
• For other advertising or marketing of our own or our affiliates' products and services.
• To help maintain the safety, security, and/or integrity of our business, Website, Products, Services, databases, and other technology assets.
• For internal testing, research, analysis, and product development, including to develop and improve our Website and application, and to develop, improve, or demonstrate our Products and Services.
• To perform services on behalf of a third-party, such as facilitating clinical consultations with Medical Group, submitting laboratory orders to partner diagnostic labs, and transmitting prescription information to partner pharmacies.
• As otherwise described to you when collecting your Personal Information or as otherwise set forth by law.

How do we share your Personal Information?

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:

• Our business purposes: We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including social media companies, analytics companies, behavioral advertising companies, and government entities. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
• With your consent: We may share your Personal Information if you request or direct us to do so.
• Compliance with law: We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• Business transfer: We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
• To enforce our rights: We may share your Personal Information to enforce our Terms and Conditions, and to ensure the safety and security of our Services and our users.
• De-identified information: We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or any other purpose permitted by law.
• To market our Products and Services: We may share your Personal Information with affiliates and third parties to market our Products and Services.
• Third-Party Analytics: We use Google Analytics and Facebook Pixel to understand and evaluate how visitors interact with our Platform and/or the Services. These tools help us improve our Platform and/or the Services, performance, and your experience.

Your choices about how we share your Personal Information

This section of our Privacy Notice provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

If you do not wish to have your email address used by SPHERE HEALTH to promote our own Products and Services, you can opt out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by logging into your Account Preferences page. This opt-out does not apply to information provided to SPHERE HEALTH as a result of a product purchase or your use of our Platform or the Services. You may have other options with respect to marketing and communication preferences through our Platform.

You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests.

How do I access and correct my Personal Information?

You can review and change your Personal Information by logging into our Services and visiting your account Settings on our Platform. You may also Contact Us to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your Personal Information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

This Privacy Notice applies to all personal uses of our Platform. You should not use the Platform or the Services if you do not agree to this Privacy Notice and the Terms and Conditions.

SPHERE HEALTH operates subject to state and federal regulations, and the Platform and/or the Services may not be available in your state. You represent that you are not a person barred from enrolling for or receiving the Services under the laws of the United States or other applicable jurisdictions in which you may be located. Access to and use of the Platform and/or the Services is limited exclusively to users located in states within the United States where the Platform and/or the Services is available. The Platform and/or the Services are not available to users located outside the United States. Accessing the Platform and/or obtaining the Services from jurisdictions where content is illegal, or where we do not offer the Platform and/or the Services, is prohibited.

SPHERE HEALTH understands the importance of protecting children's privacy in the interactive online world. Our Platform is not designed for, or intentionally targeted at, children 18 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 18. No one under the age of 18 should submit any Personal Information to the Platform, and if we learn that we have collected or received Personal Information from a child under 18, we will delete that information. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided us with their Personal Information, you may Contact Us to request that the Personal Information be deleted.

Some web browsers have a "Do Not Track" feature. This feature allows your web browser to tell websites you visit that you do not want your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.

However, certain web browsers and browser extensions permit you to broadcast the Global Privacy Control signal ("GPC Signal") as specified at https://www.globalprivacycontrol.org. We honor the GPC Signal and will limit the Personal Information or other information we collect and how we use your Personal Information or other information, as required by applicable law.

We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.

The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Platform, in your operating system, or mobile device.

California Civil Code Section 1798.83 (California's "Shine the Light" law) permits users of our Platform and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information for the immediately prior calendar year (e.g., requests made in 2026 will receive information regarding such activities in 2025). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

We may update our Privacy Notice periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Notice on this page with a notice that the Privacy Notice has been updated on our Website's homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account or through a notice on the Website. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically accessing the Platform and reviewing this Privacy Notice to check for any changes.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Notice or otherwise need to contact us, you may contact us at the contact information below or through the "Contact Us" page on the Platform.