1. Introduction
Refresh MD and its affiliates (“Refresh MD,” “we,” “us,” or “our”) respect your privacy and are committed to protecting it through this Privacy Policy.
This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit or use our website located at refreshmd.co and any related services, applications, or platforms (collectively, the “Platform” or “Services”).
By accessing or using the Services, you agree to this Privacy Policy. If you do not agree, you should not use the Services.
2. Scope of Policy
This Privacy Policy applies to:
- Website visitors
- Patients and prospective patients
- Customers purchasing services or products
- Individuals interacting with us electronically, in person, or via mobile services
It does not apply to third parties, including medical providers, labs, or pharmacies, who may have separate privacy obligations.
3. HIPAA & Protected Health Information (PHI)
3.1 Relationship to HIPAA
Refresh MD is not always a “Covered Entity” under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). However:
- We may act as a Business Associate to licensed medical providers, pharmacies, or labs
- Certain partners (e.g., physicians, nurse practitioners) are Covered Entities
- Protected Health Information (“PHI”) may be created, transmitted, or stored through our platform
3.2 When HIPAA Applies
When Refresh MD acts as a Business Associate:
- We comply with applicable HIPAA requirements
- PHI is used only for treatment, payment, or healthcare operations
- We maintain Business Associate Agreements (BAAs) where required
3.3 Non-PHI Data
The following are generally not PHI:
- Name, email, phone number (when used for account creation)
- Payment details
- General website usage data
This information is governed by this Privacy Policy and applicable state laws.
3.4 Provider-Controlled Data
Medical providers you interact with maintain their own:
- Medical records
- Notice of Privacy Practices
You acknowledge that your provider—not Refresh MD—controls clinical decision-making and certain health data usage.
4. Information We Collect
4.1 Personal Information
We may collect:
- Full name
- Email address
- Phone number
- Mailing/billing address
- Date of birth
- Government ID (for verification)
- Payment information
4.2 Health Information
When applicable, we may collect:
- Medical history
- Symptoms and conditions
- Treatment information
- Lab results
- Provider communications
- Images or videos submitted for care
4.3 Technical & Usage Data
Automatically collected data includes:
- IP address
- Device identifiers
- Browser type
- Pages visited
- Session duration
- Referral sources
4.4 Location Data
We may collect geolocation data to:
- Verify service eligibility
- Dispatch mobile providers
- Ensure regulatory compliance
5. How We Collect Information
We collect information:
- Directly from you (forms, intake, purchases)
- From healthcare providers and partners
- From third-party verification vendors
- Through cookies, pixels, and analytics tools
6. How We Use Information
We use information to:
Service Delivery
- Provide medical and wellness services
- Coordinate care with providers
- Process payments
Operations
- Maintain accounts
- Provide customer support
- Improve platform performance
Compliance & Legal
- Verify identity and eligibility
- Comply with federal and state laws
- Prevent fraud and abuse
Marketing (Non-PHI Only)
- Send promotions (where permitted)
- Improve outreach and engagement
We do NOT use PHI for marketing without authorization.
7. Disclosure of Information
We may disclose information to:
Healthcare Providers
- Physicians, nurses, and clinical partners
Service Providers
- Payment processors
- IT infrastructure providers
- Analytics and security vendors
Legal & Regulatory
- Government authorities when required
- Law enforcement with valid process
Business Transfers
- In connection with mergers, acquisitions, or asset sales
Important Restriction
We do NOT sell personal or medical information.
We do NOT share mobile/SMS data for marketing purposes.
8. Data Retention
We retain information:
- As long as necessary to provide services
- To comply with legal obligations
- To resolve disputes and enforce agreements
Medical records may be retained per:
- California law (generally 7+ years)
- Nevada law (varies depending on provider type)
9. Data Security
We implement administrative, technical, and physical safeguards including:
- Encryption (in transit and at rest where applicable)
- Access controls
- Secure data storage systems
However, no system is completely secure. Use of the Platform is at your own risk.
10. Your Privacy Rights
10.1 California (CCPA/CPRA)
California residents have the right to:
- Know what personal data is collected
- Access and receive a copy
- Request deletion
- Correct inaccurate information
- Opt-out of data “sale” or sharing (we do not sell data)
- Limit use of sensitive personal information
10.2 Nevada Privacy Rights
Nevada residents may:
- Request that we not sell personal data (we do not sell it)
10.3 Exercising Rights
You may submit requests via:
- Website contact form (refreshmd.co)
- Email: Info@refreshmd.co
- Phone: 702-992-0843
We may verify your identity before processing requests.
11. Cookies & Tracking Technologies
We use:
- Cookies
- Pixels
- Analytics tools (e.g., Google Analytics)
You may control cookies via browser settings, though some features may not function properly.
12. Minors
- Services are intended for individuals 18+
- Minors may only use services with parent/guardian consent
- We do not knowingly collect data from children under 13
13. Third-Party Services
We are not responsible for:
- Third-party websites
- External providers
- Linked platforms
Review their privacy policies separately.
14. Do Not Track Signals
We do not currently respond to “Do Not Track” browser signals.
15. Changes to This Policy
We may update this Privacy Policy periodically. Updates will be posted with a revised “Last Updated” date.
Continued use of the Services constitutes acceptance of changes.
16. Contact Information
If you have questions or requests:
Refresh MD
Website: refreshmd.co
Email: Info@refreshmd.co
Phone: 702-992-0843
17. California Privacy Addendum (CCPA/CPRA)
This section supplements the Privacy Policy for California residents.
Categories of Personal Information Collected
- Identifiers (name, email, IP address)
- Customer records (billing, contact info)
- Commercial data (transactions)
- Internet activity (usage data)
- Geolocation data
Sources
- Directly from users
- Automatically collected
- From service providers
Use of Information
- Service delivery
- Account management
- Fraud prevention
- Legal compliance
Sharing
Disclosed to:
- Service providers
- Healthcare partners
- Analytics vendors
Your Rights
- Right to Know
- Right to Delete
- Right to Correct
- Right to Non-Discrimination
Requests can be submitted via contact details above.
18. Nevada-Specific Notice
Under Nevada law (NRS 603A):
- We do not sell personal information
- Nevada residents may submit a verified request to opt out of any future sale
Telehealth Consent
By using Refresh MD services, you consent to receiving healthcare services via telehealth. Telehealth involves the use of electronic communications to enable healthcare providers to diagnose, treat, and educate patients remotely.
Acknowledgments
You understand and agree that:
- Telehealth may involve risks such as technical failures
- Your provider may determine telehealth is not appropriate
- You may withdraw consent at any time
- All applicable privacy laws, including HIPAA, apply
Consent
By proceeding, you voluntarily consent to telehealth services and acknowledge understanding of the risks and benefits.
SMS and Communications Consent
By providing your phone number, you consent to receive communications from Refresh MD, including:
- Appointment confirmations and reminders
- Service-related notifications
- Customer support messages
- Marketing and promotional messages, including special offers, discounts, new services, and company updates
Terms
- Message frequency may vary
- Message and data rates may apply
- You may opt out at any time by replying STOP
- You may request help by replying HELP
We do not share phone numbers with third parties or affiliates for their own marketing purposes.
Consent
No mobile information will be shared with third parties or affiliates for marketing/promotional purposes. All SMS opt-in requests include text messaging originator opt-in data and consent; this information will not be shared with third parties.
By providing your contact information, you agree to receive transactional and marketing communications from Refresh MD as described above, including appointment reminders, service notifications, customer support messages, promotional offers, discounts, and company updates. Message frequency may vary. Message and data rates may apply. You may opt out at any time by replying STOP or request assistance by replying HELP. Your consent is not a condition of purchasing any goods or services.