Privacy Policy

Effective: June 22, 2026

This Privacy Policy describes the data protection practices of Formula Industries, Inc. and its affiliates (collectively, “Formula”, “Formula Health”, “we,” “our,” or “us”), including when you visit any Formula Health website that links to this Privacy Policy (collectively, our “Websites”), or otherwise provide data to Formula Health. We refer to the Websites and other services provided by Formula Health together in this Privacy Policy as the “Services.”

We operate a technology platform that connects licensed healthcare provider organizations (“Clinics”) with pharmacy partners to facilitate the preparation and fulfillment of medical products, including supplements and medications, for end user patients of those Clinics. Our direct customers are Clinics. This Privacy Policy applies to Clinics and other visitors to our website or any other party that may interact with our Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

THE INFORMATION WE COLLECT AND THE SOURCES OF SUCH INFORMATION

We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

1. Information You Provide to Us

We collect a variety of information that you provide directly to us. For example, we collect information from you through:

• Account and product registration and administration of your account
• Questions, communications, or feedback you submit to us via forms or email
• Your participation in research and surveys
• Requests for customer support and technical assistance
• Uploads or posts to the Services

The types of data we collect directly from you includes:

• Name, address, telephone number, and email address
• National Provider Identifier, state licensure number and other applicable identifying information and expiration dates thereof
• Log-in credentials, if you create an account
• Information about transactions you process using the Services
• Any other information you choose to directly provide to us in connection with your use of the Services

2. Information We Collect Through Automated Means

We collect certain information about your use of the Services and the devices you use to access the Services. As discussed further below, we and our service providers may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

Our Websites. When you use our Websites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, error logs, and other similar information.

Location Information. When you use the Services, we may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device.

Our Use of Cookies and Similar Online Tools. To collect the information discussed in this Section, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies.

3. Our Usage of Collected Information

PURPOSES FOR HOW WE USE YOUR INFORMATION

In connection with providing you with the Services, we may use your information for our business purposes to:

• Carry out, improve, and manage the Services and, as applicable.
• Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base.
• Communicate with you about the Services, your use of the Services, or your inquiries related to the Services.
• Perform tasks on behalf of and according to instructions of a third party, such as payment processors or other third party service providers.
• Communicate with you by email, postal mail, or phone about our Services.
• Provide you with technical support and customer service.
• Verify your identity and administer your account.
• Ensure that content from our Services is presented in the most effective manner for you and for your computer or device.
• Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
• Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

Combined Information

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy.

Aggregate/De-Identified Data

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

ONLINE ANALYTICS AND ADVERTISING

We may use third-party web analytics services (such as those of Google Analytics and MixPanel) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you.

HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We may share your information for our business purposes in the following ways:

Affiliates and Subsidiaries

We may share information we collect within any Formula member or group (i.e., our subsidiaries and affiliates) to deliver products and services to you, ensure a consistent level of service, enhance our Services, and your customer experience.

Pharmacy Partners

We may share information provided by Clinics with pharmacy partners as necessary to fulfill orders and ship medical products to end patients. Such sharing is performed on behalf of, and at the direction of, the applicable Clinic. We only share end-patient Protected Health Information with pharmacies or other third parties as directed by the relevant Clinic, as may be applicable to perform Services requested by you or as otherwise permitted under HIPAA.

Service Providers

We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services to us, including analytics, research, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services.

Protection of Formula Health and Others

By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to comply with legal process, respond to claims, or protect the rights, property or personal safety of Formula Health, its agents, users and/or the public.

YOUR RIGHTS

Depending on your location and applicable law, you may have the following rights with respect to your customer information:

• Access. You may request a copy of the information we hold about you.
• Correction. You may request that we correct inaccurate or incomplete information about you.
• Deletion. You may request that we delete your information, subject to certain legal obligations.
• Data Portability. Where applicable, you may request that we provide your information in a structured, machine-readable format.
• Restriction. You may request that we restrict the processing of your information in certain circumstances.

To exercise any of these rights, please contact us at support@formula.health. We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before fulfilling your request.

MOBILE INFORMATION SHARING

Formula Health will not share your contact information with third parties or affiliates for marketing or promotional purposes under any circumstances. No mobile information (including phone numbers collected for SMS communications) will be shared with third parties or affiliates for marketing or promotional purposes. All categories of opt-in-data and consent records are kept confidential and are not sold, rented, or transferred outside of Formula Health and the service providers necessary to deliver SMS notifications on our behalf.

YOUR MARKETING CHOICES

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails.

HIPAA COMPLIANCE

Formula Health is committed to complying with the Health Insurance Portability and Accountability Act (HIPAA). We implement appropriate safeguards to protect the privacy and security of protected health information.

HOW WE PROTECT YOUR INFORMATION

Formula takes a variety of technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password that enables you to access the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the Privacy Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.

LEGITSCRIPT COMPLIANCE AND LICENSED PHARMACY PARTNERS

We partner exclusively with pharmacies that are licensed and in good standing in their applicable jurisdictions. The Services do not facilitate the prescribing or dispensing of prescription medications or other products outside of a valid patient-provider relationship. All prescription products are dispensed solely pursuant to valid prescriptions issued by licensed healthcare providers in compliance with applicable federal and state pharmacy laws. End patients access prescription services only through their treating Clinic and its licensed healthcare providers. Formula Health is a technology platform and is not itself a licensed healthcare provider, pharmacy, or Covered Entity under HIPAA.

CONTACTING US

If you have any questions about this Privacy Policy or Formula’s privacy practices, please contact us at support@formula.health.