Effective: March 25, 2026

Dr. David Wellness (“Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information obtained from users of www.drdavidwellness.com (the “Website”). By using the Website, you consent to the data practices described in this Policy. This Privacy Policy is incorporated into and forms part of our Terms of Service.

1. INFORMATION WE COLLECT

1.1 Information You Provide Directly

• Full name, date of birth, and sex/gender
• Mailing and shipping address, email address, and telephone number
• Account username and password
• Medical history, current medications, allergies, and health conditions you disclose during intake or consultation
• Prescription information and pharmacy records
• Government-issued identification (where required for prescription services)
• Lab results or other diagnostic information you choose to upload or share
• Written communications you send to us, including emails, chat messages, and support requests

1.2 Payment Information

Payment card information is processed exclusively by our third-party payment processor. We do not store full credit or debit card numbers on our servers. We retain billing address, transaction amounts, and last four digits of your card for our records.

1.3 Automatically Collected Data

• IP address, browser type, device type, and operating system
• Pages visited, links clicked, and duration of Website sessions
• Referring URLs and exit pages
• Cookie identifiers, pixel data, and session identifiers
• Approximate geographic location derived from IP address

1.4 Sensitive Health Information

Because we offer health and wellness products and services, we necessarily collect health and medical information, which may constitute “sensitive personal information” under applicable state privacy laws and may include Protected Health Information (“PHI”) regulated by HIPAA. By using this Website, you expressly consent to our collection and use of your health information as described in this Privacy Policy and in any separate HIPAA Notice of Privacy Practices provided to you.

2. HOW WE COLLECT INFORMATION

• Directly from you when you register an account, complete checkout, submit intake or consultation forms, or contact our support team.
• Automatically through cookies, web beacons, pixels, session recording tools, and analytics platforms when you interact with the Website.
• From third parties, including pharmacy partners, licensed healthcare providers, payment processors, advertising platforms, and analytics providers.

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Process orders, manage subscriptions, and fulfill Product shipments.
• Facilitate telehealth consultations and coordinate care with healthcare providers and pharmacy partners.
• Verify your identity and eligibility to receive prescription Products.
• Send transactional communications including order confirmations, shipping notifications, and prescription status updates.
• Send marketing and promotional communications if you have opted in (you may opt out at any time).
• Improve, personalize, and optimize the Website, our products, and our services.
• Comply with applicable legal and regulatory obligations, including pharmacy laws, DEA regulations, state licensing requirements, and tax reporting.
• Detect, investigate, and prevent fraud, abuse, unauthorized access, and violations of our Terms.
• Protect the rights, property, and safety of the Company, our users, and the public.

4. COOKIES & TRACKING TECHNOLOGIES

We use cookies, web beacons, pixels, and similar tracking technologies to operate and improve the Website and support our marketing efforts. Categories of technologies we use:

• Essential/functional cookies: Required for basic Website operation, security, and user authentication. These cannot be disabled without impairing Website functionality.
• Analytics cookies: Help us understand user behavior and improve the Website (e.g., Google Analytics, Hotjar).
• Advertising/marketing pixels: Enable targeted advertising and retargeting on third-party platforms (e.g., Meta Pixel, Google Ads, TikTok Pixel).
• Session recording tools: May record mouse movements, clicks, scrolls, and form interactions to help us identify and fix usability issues.

You may control cookie settings through your browser. Note that disabling certain cookies may affect Website functionality. Where required by applicable law (including the California Consumer Privacy Act / CPRA), we honor opt-out signals such as the Global Privacy Control (GPC). You may also opt out of certain advertising cookies through industry opt-out tools such as the NAI Opt-Out Tool.

5. DISCLOSURE OF YOUR INFORMATION

We may share your personal information with:

• Healthcare providers: Licensed physicians, nurse practitioners, and pharmacists involved in your care and prescription fulfillment.
• Pharmacy partners: To dispense, package, and ship prescription Products to you.
• Payment processors: To securely process payment transactions.
• Service providers and vendors: Including IT providers, cloud storage, customer service platforms, email service providers, and marketing vendors, all of whom are contractually obligated to protect your information and use it only for the purposes we specify.
• Legal and regulatory authorities: Law enforcement, courts, government agencies, or regulators when required by applicable law, valid legal process, or to protect the rights, property, or safety of the Company, users, or the public.
• Business successors: In connection with a merger, acquisition, sale of all or substantially all assets, or other corporate transaction. We will provide notice of any such change and any choices available to you.

We do NOT sell your personal information to third parties for their own independent marketing or commercial purposes.

6. HIPAA & PROTECTED HEALTH INFORMATION

To the extent the Company or its affiliated providers are subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), your Protected Health Information (“PHI”) will be handled in accordance with all applicable HIPAA and HITECH requirements and any Notice of Privacy Practices separately provided to you. In the event of any conflict between this Privacy Policy and our HIPAA obligations with respect to PHI, our HIPAA obligations shall govern.

You have certain rights with respect to your PHI, including the right to request access, amendment, accounting of disclosures, and restrictions on use. Please contact us to exercise these rights.

7. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Policy and to comply with our legal obligations. Medical records and related information may be retained for a minimum of 7 to 10 years as required by applicable state and federal law. When data is no longer required, it is securely deleted or anonymized.

8. DATA SECURITY

We implement commercially reasonable administrative, technical, and physical security measures designed to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. Our security practices include SSL/TLS encryption for data transmission, access controls and authentication requirements, and secure hosting on reputable cloud infrastructure.

NO INTERNET TRANSMISSION OR ELECTRONIC STORAGE METHOD IS 100% SECURE. WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR INFORMATION. YOU TRANSMIT INFORMATION TO US AT YOUR OWN RISK.

In the event of a data breach that triggers applicable notification requirements, we will notify you as required by law.

9. YOUR PRIVACY RIGHTS

9.1 California Residents — CCPA / CPRA

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you, the sources of collection, the business purpose for collection, and the categories of third parties with whom it is shared.
• Right to Delete: Request deletion of your personal information, subject to certain legal exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: We do not sell personal information. We may share certain identifiers with advertising partners for targeted advertising; you may opt out via our Cookie Settings or by contacting us.
• Right to Limit Use of Sensitive Personal Information: Request that we limit the use and disclosure of sensitive personal information (including health data) to purposes permitted by the CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise these rights, contact us as described in Section 13. We will respond within 45 days of receipt of a verifiable consumer request (extendable by an additional 45 days with notice). We may require verification of your identity before processing requests.

9.2 Residents of Other States

Residents of Virginia, Colorado, Connecticut, Texas, Florida, and other states with comprehensive consumer privacy laws may have analogous rights, including rights to access, correct, delete, and opt out of certain data uses. Please contact us to exercise any applicable state privacy rights. We will respond as required by the applicable law of your state of residence.

10. CHILDREN’S PRIVACY

This Website is not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected personal information from a person under 18, please notify us immediately and we will take prompt steps to delete such information.

11. THIRD-PARTY WEBSITES

This Privacy Policy applies solely to this Website. It does not govern the privacy practices of any third-party websites linked from the Website. We are not responsible for the data collection, use, or security practices of any third-party site. We encourage you to review the privacy policies of any third-party sites you visit.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. Material changes will be communicated by updating the “Last Updated” date at the top of this Policy and, where appropriate, by email notification or a prominent notice on the Website. Your continued use of the Website following the posting of changes constitutes your acceptance of the revised Policy.

13. CONTACT — PRIVACY REQUESTS

For questions about this Privacy Policy, to exercise your privacy rights, or to submit a data access or deletion request, please contact our Privacy Team:

Dr. David Wellness — Privacy Department
Website: www.drdavidwellness.com
Email: support@drdavidwellness.com
Mailing Address: 145 S Glenoaks blvd suite 1072 Burbank, CA 91502
Phone: 818-570-1640

We will acknowledge receipt of your request within 10 business days and respond within the timeframe required by applicable law.