Privacy Policy

Effective Date: July 15, 2026  |  Last Updated: July 15, 2026

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SERVICES OR WEBSITE.

Legal-review notice: This is a business draft for review by qualified privacy, healthcare, and telehealth counsel before publication. It must be confirmed against FOUNDATION's actual vendors, workflows, data practices, provider arrangements, and jurisdictions of operation.

Table of Contents

1. Introduction

Welcome to FOUNDATION.

At FOUNDATION TELE-HEALTH, LLC ("FOUNDATION," "we," "our," or "us"), protecting your privacy is fundamental to the trust you place in us. We recognize that health information is among the most personal and sensitive information you may share, and we are committed to safeguarding it through administrative, technical, and physical measures designed to protect its confidentiality, integrity, and availability.

This Privacy Policy explains how FOUNDATION collects, uses, stores, shares, and protects Personal Information and, where applicable, Protected Health Information ("PHI") when you visit or use our website, patient portal, digital services, telehealth services, communications, programs, products, or other services (collectively, the "Platform" and the "Services").

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform or provide Personal Information through it.

IMPORTANT HIPAA NOTICE: Our Notice of Privacy Practices is a separate document that describes how PHI may be used and disclosed by FOUNDATION, affiliated professional entities, and healthcare providers in accordance with the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and applicable state law. If this Privacy Policy conflicts with the Notice of Privacy Practices with respect to PHI, the Notice of Privacy Practices controls.

2. Scope of This Privacy Policy

This Privacy Policy applies to information collected through tryfoundation.co, any FOUNDATION-owned website, patient portal, mobile or web-based experience, telehealth interface, email, SMS or text messaging, telephone, customer support, digital assessment, wellness program, and other interaction with FOUNDATION.

This Privacy Policy does not apply to third-party websites, applications, physician practices, pharmacies, laboratories, payment processors, or other organizations that maintain their own privacy policies. Links to third-party services do not constitute an endorsement of their privacy practices.

3. Definitions

Account means a user or patient account created to access the Platform or Services.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identifiable individual or household, as defined by applicable law.

Protected Health Information or PHI has the meaning assigned under HIPAA and generally includes individually identifiable health information maintained or transmitted by a covered entity or business associate.

Platform means FOUNDATION's websites, patient portal, applications, digital interfaces, and related technology services.

Services means telehealth consultations, metabolic optimization and weight-management programs, healthcare coordination, prescription fulfillment coordination, educational resources, support services, and other offerings made available through FOUNDATION.

Service Provider means a third party that processes information on FOUNDATION's behalf to support the Platform or Services.

4. Information We Collect

The information we collect depends on how you interact with FOUNDATION. We may collect the categories described below directly from you, automatically through your use of the Platform, from affiliated healthcare providers, pharmacies, laboratories, and other third parties involved in providing the Services, or from other sources permitted by law.

4.1 Information You Provide Directly

Identity information, such as your full legal name, preferred name, date of birth, sex or gender where relevant to care, photograph, and government-issued identification when required for identity verification.

Contact information, such as your email address, mobile telephone number, mailing address, and emergency contact information if provided.

Account information, such as username, password, authentication credentials, security preferences, and communication preferences.

Payment and transaction information, such as billing address, payment method, transaction history, subscription information, and refund information. FOUNDATION generally does not store full payment card numbers; payments are processed by third-party payment processors.

Communications and content, including emails, SMS messages, telephone calls, chat messages, secure portal messages, customer support requests, survey responses, feedback, and testimonials you voluntarily provide. Calls may be monitored or recorded where permitted by law for quality, training, safety, fraud prevention, and compliance purposes.

4.2 Health and Medical Information

If you seek healthcare services through FOUNDATION or affiliated healthcare providers, we may collect information necessary to evaluate eligibility, provide care, coordinate treatment, prescribe medications when clinically appropriate, monitor progress, and maintain records.

This information may include medical and surgical history; current health concerns; family history; medications; allergies; diagnoses; pregnancy status where clinically relevant; height; weight; body mass index; waist circumference; blood pressure; heart rate; laboratory results; photographs submitted for clinical review; provider notes; treatment plans; prescription and refill history; pharmacy communications; side effects; treatment adherence; and follow-up assessments.

Lifestyle information may include nutrition, exercise, sleep, stress, alcohol use, tobacco or nicotine use, recreational drug use, wellness goals, and prior weight-management or metabolic-health programs.

4.3 Metabolic Optimization and Weight-Management Information

Because FOUNDATION may provide metabolic optimization and weight-management services, we may collect information such as weight history and goals, nutrition questionnaires, exercise preferences, metabolic assessments, GLP-1 treatment history, medication tolerance, progress measurements, side effects, adherence information, and wellness milestones.

This information is used to assist licensed healthcare providers in evaluating treatment options, developing care plans, and monitoring patient progress.

4.4 Information Collected Automatically

When you use the Platform, certain information may be collected automatically, including device type, operating system, browser type and version, screen resolution, device identifiers, mobile carrier, IP address, approximate geographic location, internet service provider, referring and exit pages, pages viewed, time spent on pages, navigation patterns, searches, clicks, session duration, error logs, and performance metrics.

We use this information to operate and secure the Platform, understand usage, diagnose technical issues, prevent fraud, improve accessibility and performance, and personalize the user experience.

5. Cookies and Similar Technologies

FOUNDATION uses cookies and similar technologies, including session cookies, persistent cookies, pixels, web beacons, software development kits, local storage, and server logs, to operate the Platform, remember preferences, keep users signed in, analyze traffic, improve performance, measure communications, detect fraud, and protect security.

Some cookies are strictly necessary for the Platform to function. You may configure your browser to refuse some or all cookies or alert you when cookies are sent, but doing so may limit functionality.

Where required by applicable law, FOUNDATION honors recognized browser-based privacy preference signals, including Global Privacy Control (GPC). Additional details may be provided in a separate Cookie Policy.

6. Analytics and Third-Party Tools

FOUNDATION may use third-party analytics, hosting, security, communications, payment, identity verification, and performance tools. These providers may collect device, usage, transaction, or technical information in order to perform services on our behalf.

Payment services may include Intuit QuickBooks, Stripe, or other payment processors. Their use of information is governed by their own privacy notices and contractual obligations. FOUNDATION requires Service Providers to protect information and use it only for authorized purposes, subject to applicable law.

7. Artificial Intelligence and Automated Technologies

FOUNDATION may use artificial intelligence, machine learning, and automated technologies to support administrative efficiency, patient intake, scheduling, customer service routing, document organization, workflow automation, educational content recommendations, quality assurance, fraud detection, and internal analytics.

Where such technologies are used in connection with healthcare services, they are intended to assist - not replace - the independent medical judgment of licensed healthcare professionals. Licensed healthcare providers remain responsible for clinical decisions. Patients should not rely solely on automated responses for medical advice or emergency care.

FOUNDATION evaluates automated technologies for security, reliability, fairness, and compliance with applicable law.

8. How We Use Information

We may use Personal Information and PHI, as permitted by law, for the following purposes:

To verify identity, create and administer accounts, determine eligibility for Services, schedule appointments, facilitate telehealth consultations, coordinate treatment, support clinical evaluations, prescribe medications when clinically appropriate, coordinate with pharmacies and laboratories, monitor progress, respond to patient questions, and maintain medical and business records.

To operate, maintain, secure, authenticate, troubleshoot, personalize, and improve the Platform and Services.

To process payments, subscriptions, refunds, billing, accounting, taxes, and fraud prevention activities.

To communicate about appointments, prescriptions, refills, treatment, care coordination, billing, account security, service announcements, customer support, educational resources, wellness information, and Platform updates.

To perform quality assurance, product development, accessibility improvements, analytics, research, benchmarking, and statistical reporting, including through aggregated or de-identified information where appropriate.

To detect, prevent, and investigate fraud, abuse, cybersecurity threats, unauthorized access, and other illegal or harmful activity.

To comply with legal, regulatory, licensing, tax, accounting, audit, and contractual obligations; respond to lawful requests; resolve disputes; enforce agreements; and protect the rights, safety, and property of FOUNDATION, patients, providers, and others.

For any other purpose disclosed at the time information is collected or with your consent where required.

9. Telehealth and Clinical Services

FOUNDATION provides access to technology-enabled healthcare services through affiliated or contracted licensed healthcare professionals. Information collected for telehealth may include medical questionnaires, health history, images voluntarily submitted, consultation notes, clinical documentation, electronic prescriptions, pharmacy communications, laboratory information, and care coordination records.

Healthcare decisions are made by licensed healthcare providers based on their independent professional judgment. Use of the Platform alone does not necessarily establish a provider-patient relationship; such a relationship is established only as permitted by applicable law and the relevant provider's policies.

10. Marketing Communications

With your consent where required, FOUNDATION may send newsletters, educational materials, health insights, new-service announcements, wellness program information, company updates, and promotional offers.

You may opt out of marketing emails by using the unsubscribe link, updating available account preferences, or contacting info@tryfoundation.co. Opting out of marketing does not prevent FOUNDATION from sending transactional, security, billing, treatment, or healthcare-related communications necessary to provide Services or comply with law.

11. SMS Communications and FOUNDATION Offers

FOUNDATION operates transactional and, where separately authorized, promotional text messaging programs, including FOUNDATION Offers. By voluntarily providing your mobile number and opting in where required, you consent to receive recurring automated or non-automated text messages regarding appointments, medication updates, refill reminders, care coordination, wellness check-ins, customer support, billing, account notifications, program updates, and promotional offers.

Message frequency varies. Message and data rates may apply. Consent to receive promotional texts is not a condition of purchase.

To stop receiving text messages, reply STOP, UNSUBSCRIBE, or CANCEL to any message. You may receive one confirmation message and no further messages from the applicable program unless you later opt in again. For help, reply HELP, call (844) 694-5717, or email info@tryfoundation.co.

SMS opt-in data and consent are not sold or shared with third parties for their own marketing or advertising purposes. FOUNDATION may share your telephone number and consent status with Service Providers, platform vendors, carriers, and messaging providers solely to deliver and administer text messages. Wireless carriers are not liable for delayed or undelivered messages.

12. How We Disclose Information

FOUNDATION does not sell Personal Information for monetary compensation. We may disclose information as described below and as otherwise permitted or required by law.

Healthcare providers and professional entities. We may disclose information to physicians, nurse practitioners, physician assistants, pharmacists, laboratories, healthcare facilities, and other professionals involved in your care.

Pharmacies and laboratories. We may disclose information to fill prescriptions, coordinate delivery, process refills, resolve medication questions, and complete laboratory testing.

Service Providers. We may disclose information to vendors that provide cloud hosting, data storage, identity verification, payment processing, appointment scheduling, customer support, email, SMS, security monitoring, analytics, website hosting, auditing, and similar services.

Affiliates. We may disclose information to FOUNDATION affiliates and affiliated professional entities for authorized treatment, payment, healthcare operations, account administration, and business purposes.

Legal and safety disclosures. We may disclose information to comply with law, court orders, subpoenas, governmental requests, licensing requirements, or legal process; to prevent or investigate fraud or unlawful conduct; to protect patient safety; or to protect rights, property, and security.

Business transfers. Information may be transferred in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar transaction, subject to applicable law.

With your authorization. We may disclose information for other purposes when you authorize or direct us to do so.

De-identified and aggregated information. We may use or disclose information that has been de-identified or aggregated in accordance with applicable law for research, analytics, quality improvement, product development, and business operations.

13. HIPAA and Protected Health Information

Where FOUNDATION, affiliated professional entities, or contracted healthcare providers act as covered entities or business associates under HIPAA, PHI is used and disclosed only as permitted or required by HIPAA, HITECH, and applicable state law.

Our separate Notice of Privacy Practices explains how PHI may be used and disclosed, your rights regarding PHI, applicable legal duties, and how to submit a HIPAA privacy complaint. If there is a conflict between this Privacy Policy and the Notice of Privacy Practices regarding PHI, the Notice of Privacy Practices controls.

14. Data Security

FOUNDATION maintains administrative, technical, and physical safeguards designed to protect Personal Information and PHI from accidental loss, unauthorized access, use, disclosure, alteration, and destruction.

Safeguards may include encryption in transit, encryption of sensitive information at rest where appropriate, role-based access controls, multi-factor authentication, security monitoring and logging, vulnerability assessments, workforce training, vendor risk reviews, business continuity planning, disaster recovery procedures, and incident response processes.

No method of transmission over the Internet or electronic storage is completely secure. FOUNDATION cannot guarantee absolute security. You are responsible for protecting your credentials and promptly notifying FOUNDATION of suspected unauthorized access.

15. Data Retention

FOUNDATION retains Personal Information and PHI for as long as reasonably necessary to provide Services, maintain medical and business records, comply with legal and regulatory obligations, resolve disputes, enforce agreements, preserve litigation holds, and protect legal rights.

Retention periods vary based on healthcare record requirements, state law, tax and accounting obligations, contracts, and operational needs. When information is no longer required, FOUNDATION may securely delete, destroy, anonymize, or de-identify it in accordance with applicable law and records-management policies.

16. Your Privacy Choices and Rights

Depending on applicable law, you may have rights to access, correct, delete, or obtain a copy of certain Personal Information; withdraw consent; object to or restrict certain processing; opt out of certain targeted advertising, sale, or sharing; limit certain uses of sensitive information; and appeal certain privacy decisions.

These rights are subject to legal, medical, security, identity-verification, and record-retention limitations. Requests involving PHI are governed by HIPAA, applicable state law, and the Notice of Privacy Practices.

To submit a privacy request, email info@tryfoundation.co. FOUNDATION may verify your identity or authority before completing a request. Authorized agents may be required to provide proof of authorization, and FOUNDATION may contact the individual directly to confirm the request.

17. California Privacy Notice

This section applies to California residents to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA"), applies. Certain information is exempt from the CCPA, including PHI governed by HIPAA, medical information governed by the California Confidentiality of Medical Information Act, and other information maintained in the same manner as such information.

In the preceding 12 months, FOUNDATION may have collected identifiers; customer records; characteristics of protected classifications; commercial information; internet or electronic network activity; approximate geolocation; professional or employment information; audio or electronic communications; sensitive Personal Information, including health-related information; and inferences derived from these categories.

Sources may include you, your device or browser, healthcare providers, pharmacies, laboratories, Service Providers, advertising or analytics partners where permitted, and other lawful sources.

Business purposes include providing and improving Services, processing transactions, security, fraud prevention, quality assurance, customer support, communications, analytics, legal compliance, and the purposes described in this Privacy Policy.

California residents may have the right to know, access, delete, correct, receive portable information, opt out of sale or sharing, limit certain uses of sensitive Personal Information, and receive non-discriminatory treatment for exercising privacy rights. FOUNDATION does not sell Personal Information for monetary consideration. To exercise rights, email info@tryfoundation.co.

Where FOUNDATION uses cookies or similar technologies that constitute sharing or targeted advertising under California law, you may use available cookie settings, a 'Do Not Sell or Share My Personal Information' mechanism, or a recognized opt-out preference signal such as GPC, where legally required.

18. Additional U.S. State Privacy Rights

Residents of states with comprehensive consumer privacy laws may have additional rights, subject to applicable exemptions, including rights to access, correct, delete, obtain a portable copy, opt out of targeted advertising, sale, or profiling, and appeal a denied request.

FOUNDATION will process verified requests in accordance with applicable law. To submit a request or appeal, email info@tryfoundation.co and describe the request.

19. Do Not Track and Privacy Signals

Some browsers offer a 'Do Not Track' setting. Because there is not yet a uniform industry standard for interpreting these signals, FOUNDATION may not respond to traditional Do Not Track signals. FOUNDATION will honor legally recognized opt-out preference signals, including GPC, where required by applicable law.

20. Third-Party Platforms

The Platform may contain links to third-party websites, applications, pharmacies, laboratories, payment services, or other services outside FOUNDATION's control. This Privacy Policy does not apply to those services.

FOUNDATION DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR THIRD-PARTY PRIVACY, SECURITY, CONTENT, OR DATA-HANDLING PRACTICES. REVIEW THE PRIVACY NOTICE OF EACH THIRD PARTY BEFORE PROVIDING INFORMATION.

21. Services for Adults

FOUNDATION's Services are intended for adults. FOUNDATION does not knowingly provide Services to, or collect Personal Information directly from, individuals under 18 except where permitted by law and under appropriate parent, guardian, or healthcare-provider supervision.

If FOUNDATION learns that information was collected from a minor in violation of applicable law, we will take reasonable steps to delete it.

22. International Users

The Platform and Services are intended primarily for individuals in the United States. If you access the Platform from outside the United States, you understand that information may be transferred to, processed, and stored in the United States, where privacy protections may differ from those in your jurisdiction.

23. Changes to This Privacy Policy

FOUNDATION may update this Privacy Policy to reflect changes in Services, technology, legal obligations, or business practices. We will post the revised policy and update the Last Updated date. Where required by law, we will provide additional notice or obtain consent.

Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes acknowledgment of the revised policy to the extent permitted by law.

24. Contact Information

Questions, privacy requests, or comments regarding this Privacy Policy may be directed to:

FOUNDATION TELE-HEALTH, LLC
131 Continental Dr, Ste 305
Newark, DE 19713
Email: info@tryfoundation.co
Telephone: (844) 694-5717