Last updated: February 5, 2024

Your privacy is important to A Group of People LLC. (“A Group of People”,” “NuGrowthRX™” “we”, “us” or “our”). A Group of People is committed to protecting your privacy. This Privacy Notice applies to (i) your use of and access to the NuGrowthRX.com website, including any portions thereof available only to subscribers, and other websites that we own and operate that include this Privacy Notice (the “Site”), (ii) your use of and/or access to the mobile phone applications which we may own or operate currently or in the future (collectively, the “Mobile App”), and (iii) your use of and/or access to any content or information and other online or mobile-enabled technology, digital tools and other services and products provided by us (together with the Site and the Mobile App, the “Services”). Please read this Privacy Notice carefully as it explains our practices regarding the collection, use and disclosure of Personal Information and the choices you have associated with that information. Capitalized terms used but not defined in this Privacy Notice have the meaning given to them in our other policies (e.g., our Terms and Conditions).

Your use of our Services also is governed by our Terms and Conditions. Before using our Services, please carefully read our Terms and Conditions and this Privacy Notice. By using these Services, you consent to the collection and use of the Personal Information in accordance with this Privacy Notice. If you do not feel comfortable with any part of this Privacy Notice, you should not use or access our Services.

1. MODIFICATIONS TO THIS PRIVACY NOTICE

‍We may modify this Privacy Notice at any time, without prior notice, and changes may apply to any Personal Information we hold about you, as well as any new Personal Information collected after the Privacy Notice is modified. If we make changes, a revised Privacy Notice will be posted to our Site or Mobile App. The date of the last modified is included at the top of the page. Your continued use or re-visitation of the Services following the posting or notice of a revised Privacy Notice means that you accept and agree to the changes. Please check this page from time to time so you are aware of any changes.

2. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

‍We collect Personal Information when you use our Services. Personal Information as used in this Privacy Notice means any information that relates to you, identifies you personally or could be used to identify you including, but not limited to, your name, mailing address, email address, and telephone number. The types of Personal Information that we collect include, but are not limited to, the information you provide to us and information from third parties, including our business partners, as explained further below.

‍What Information We Collect

‍The Personal Information we collect from you may include:

• Information that you provide by filling in forms on our Site or Mobile App, including your name, mailing address, email address, telephone number, gender, age, date of birth, language preference, resident status, leisure and interests, and occupation, title, job description, and employer.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your search queries on the Site or Mobile App.
• Information that you provide when you contact one of our customer service representatives, which may include your name, mailing address, email address, telephone number, gender, age, date of birth, language preference, resident status, leisure and interests, and occupation, title, job description, and employer.
• Your IP address, geolocation information, and mobile device ID (if you use your mobile device to access our Site or Mobile App).
• Billing, payment and shipping information. All credit card, debit card and other monetary transactions on or through the Services occur through an online payment processing application(s) accessible through the Services. This online payment processing application(s) is provided by our third-party online payment processing vendor, Stripe and/or Square.
• Your electronic signature.
• Photographic or video images submitted for identification or non-diagnosis or treatment purposes.Information about third parties that you refer to us (e.g., name, email, and/or other contact information, relationship).
• Statements or content (e.g., comments, videos, photographs, images) and information about such statements or content, which you submit or publish on or through the Services or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram).
• Information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, and social media apps).
• Other information we may specifically request or you may voluntarily provide.

We also collect certain medical information on behalf of NuGrowthRX’s Providers, which may include, but is not limited to:
• Descriptions (and/or photographs) of medical or health conditions (e.g., information about physical or psychological state of health, disease state, medical history, and medical treatment or diagnosis by a health care professional).
• Date of visit.
• Images or videos you share for diagnosis or treatment purposes.
• Communications with your Providers.

‍How We Collect Information

‍We may collect Personal Information and other information directly from you when you:
• Visit the Site, or Mobile App or access or use the Services.
• Register with or subscribe to the Services or any products or services available through the Services.
• Sign in or log into the Services or a portal for subscribers on the Site or Mobile App.
• Link to the Services via a social medial network.
• Allow the Services to access, upload, download, import or export content found on or through, or to otherwise interact with, your device or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, and your mobile device service provider).
• Process a payment through the Services.

We also may collect Personal Information and other information directly from you:

• Whenever we ask you for such information, for example, when you answer an online survey or questionnaire.
• If you or a third party send us a comment, message or other communication (such as an email, letter, phone call, or voice message) about you or your activities on or through the Site and/or Mobile App, then we may collect any Personal Information or other non-personal information in connection with those communications.

We may collect certain information from:

• Providers who provide treatment or other services to you in connection with our Services. This information may include diagnoses, treatment plans (including prescription details) and notes, and is accessible and visible through certain components of the Services.
• Third parties with whom we work to provide you with certain services (including, for example, sub-contractors, analytics providers, advertising networks, and search information providers).

We may combine information we receive from other sources with information you give to us and information we collect about you.

When you interact with our Site or account on a social media platform,
• We may collect the Personal Information that you or the Site make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such Personal Information that we are permitted to collect by those social media platforms. When you access our Site through social media services or when you connect the Services to social media services, you are authorizing NuGrowthRX™ to collect, store, and use such information and content in accordance with this Privacy Notice.

3. COOKIES AND OTHER TRACKING TECHNOLOGY

Information Collected Automatically

‍As with many other websites and applications, as you navigate through and interact with our Site or Mobile App, we may use automatic information collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Site, including, but not limited to, traffic information, location information, logs and other communication information, date and time of access, frequency, application crashes, and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, device make and model, carrier, operating system, host domain, data connection type, advertising IDs, software development kit/application programming interface, and browser type.
• Information about your preferences to make your use of the Services more productive, via the use of cookies.

We may use cookies, embedded scripts, pixel tags, plugins, widgets, and other similar tracking technologies (“Tracking Technologies”) to collect additional Personal Information automatically as you interact with the Site and to personalize your experience with our Site. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (known as “behavioral tracking”).

‍Cookies

‍“Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use cookies to customize the Services for each user and to provide functional features, including to maintain users’ logged-in status, to provide social media features, and to analyze our traffic We also share information about your browser’s use of our Site with our social media, advertising and analytics partners. We use the information from cookies to provide services better tailored to our users’ needs.

We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Services easier (such as by remembering your User ID), to recognize you when you return to our Site or Mobile App, to track your interaction with the Services, to enhance your experience with the Services, to remember information you have already provided, to collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests, and to provide a secure browsing experience during your use of our Site or Mobile App. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e., after you have finished browsing).

We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from NuGrowthRX™. The following types of cookies are used on our Site:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site and confirm for us whether your browser supports cookies. Without these cookies, some elements of our Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, .these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
• Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You may choose to disable these cookies.
• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same advertisement from continuously reappearing, ensuring that advertisements are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. For example, these cookies allow our third-party advertising partners to experiment with advertisement efficiency across websites, register and report users’ actions after viewing or clicking on an advertisement with the purpose of measuring the advertisement’s efficacy, and track a user’s interest in specific products or events across multiple websites to measure advertising efforts and facilitate referral-fee payments. You may choose to disable the use of these cookies as set forth below.

‍Cross-Device Tracking

‍We use data analytics companies, advertising networks, or social media companies, and features offered by data analytics services to engage in “cross-device tracking,” which occurs when platforms, publishers, and advertising technology companies try to connect a consumer’s activity across smartphones, tablets, desktop computers, and other connected devices. The goal of cross-device tracking is to enable companies to link a consumer’s behavior across devices.

‍Analytics

‍We may use third-party Service Providers (defined below) to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their information from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

‍Other Tracking Technologies

‍We also may use Tracking Technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device make and model, IP address used to connect your computer to the Internet, your data connection type, your browser type and version, operating system and platform, date and time stamp for your visit to the Site, webpages viewed, content searched for, and other relevant statistics, and to assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

4. HOW WE USE YOUR INFORMATION

‍We will only use your Personal Information as described in this Privacy Notice or as disclosed to you prior to such processing taking place. We may use information collected about you, including Personal Information, in the following ways:

• Verifying your identity.
• Confirming your location.
• Providing you with services and products, including to administer your account.
• Maintaining, improving, and developing Services.
• Matching you with a provider licensed in your state of residence.
• Providing safety and security features.
• Communicating with you to provide updates, service-related notifications, and promotions.
• Providing customer services, including in order to respond to your inquiries and/or complaints.
• Processing your purchases and transactions.
• Complying with valid legal requests and addressing legal issues and disputes.
• Protecting you, others, and our business, including, without limitation, investigating and responding to suspected illegal activities and fraud.
• Creating and administering surveys.
• Combatting malware, malicious activities or other security risks.
• Detecting and removing spammers, non-compliant images, etc.
• Signing you up for our newsletters and/or other communications consistent with your preferences.
• Tailoring your experience on the Site or Mobile App and/or otherwise customizing what you see when you visit and use the Site or Mobile App.
• Analyzing traffic to and through the Services.
• Analyzing user behavior and activity on or through the Services.
• Conducting research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research, and other activities related to NuGrowthRX™, the Services or products and services offered via the Services.
• Monitoring the activities of you and others on or through the Services.
• Placing and tracking orders for products or services on your behalf.
• Protecting or enforcing our rights and properties, and the rights and properties of others (which may include you).
• To comply with applicable federal, state, and other laws and regulations.
• For any other purpose disclosed to you prior to you providing us your Personal Information or which are reasonably necessary to provide the Services or other related products and/or services requested.

We also may use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at info@nugrowthrx.com to opt-out.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

5. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

‍We may share or disclose your Personal Information in the following circumstances:

• Website/e-commerce Service Providers. We may employ other companies and individuals to facilitate our Site (“Service Providers”), provide services on our behalf, or assist us in analyzing how our Site is used. The Service Providers have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Services. We may disclose your Personal Information to the Providers; and certain vendors in order to fulfill the purpose(s) for which you have provided this Personal Information and to collect payments on their behalf.
• Within Our Corporate Organization. We may share your Personal Information with our subsidiaries and affiliates in order to provide you with the Services and take actions based on your requests.
• Corporate Transactions. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Site or Mobile App users and members is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your Personal Information.
• Analytics. We may share aggregated, de-identified information (for example, aggregated trends about the general use of our Site) publicly and with our affiliates, subsidiaries, and partners. This information will not include medical information.
• Third-Party Advertisers. In certain circumstances, we may share your Personal Information with third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• Consent. We may disclose your Personal Information for any purpose with your consent.
• As Required by Law. Under certain circumstances, your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. We will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that we may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce our Terms and Conditions and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of NuGrowthRX™, its employees, its users, its clients, and the public.
• For any other purpose disclosed by us when you provide the information.
• With respect to de-identified information, for any purpose without restriction.

6. PUBLICLY DISCLOSED INFORMATION

Name and Likeness

We may publish your name, voice, likeness and other Personal Information. NuGrowthRX™ may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. Please review our Terms and Conditions for more information.

‍Profiles

‍A user’s profile page may be set up to display information such as the user’s display name, images, location (city/state/country), groups that the user has joined and optional information added by the user. NuGrowthRX™ uses profile information be presented to others permitted to view that information on the Services. Users may have the ability to manage their public profile and adjust their profile preference settings. Users should be aware that these settings are for convenience only, and may not be error free. Further, other users that have access may repost or otherwise make public user’s information or content. Accordingly, discretion and good judgment should be exercised when posting information or content as part of user’s profile.

CHOICES REGARDING MARKETING AND PERSONAL INFORMATION

‍We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

‍Marketing Communications Choices
‍
‍If you do not wish to have your email address, mobile phone number, or other contact information used by us to promote our own or third parties’ products or services, you can opt-out by sending an email stating your request to info@nugrowthrx.com. You also may choose to stop receiving our promotional or marketing emails and/or SMS/MMS text messages by following the “unsubscribe” instructions included in these communications.

Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

‍Update Personal Information
‍
‍We are committed to ensuring that your Personal Information is kept accurate and up to date. However, it is up to you to update it with any changes. You may send us an email at info@nugrowthrx.com to request an update to any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

‍Requests to Delete Personal Information
‍
‍If you are no longer an active user and no longer wish to have your Personal Information be processed, you may request to delete your Personal Information, subject to certain limitations, by emailing us at info@nugrowthrx.com.

‍Cookie Choices

‍Your browser may provide you with the option to refuse some or all browser cookies. You also may be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing the Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email stating your request to info@nugrowthrx.com. You can also opt-out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1).

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:
‍
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Android Browser
• Opera (Desktop)

‍Do Not Track

‍Some internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

‍Notice to California Residents

‍California Civil Code § 1798.83 permits our users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@nugrowthrx.com. Please note that we are only required to respond to one such request per user per year.

8. DATA SECURITY

‍We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site or Mobile App. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or Mobile App.

9. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES

‍The Site and Mobile App may be linked to, rely on, and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including third-party services. The Site and Mobile App also may feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services, and platforms operated by third parties that are linked to, rely on and/or integrated with the Site or Mobile App or for the privacy practices of third-party advertising companies. Once you leave this Site or Mobile App via a link, access a third-party service or click on an advertisement, you should check applicable privacy policies to determine, among other things, how related companies process the Personal Information they may collect about you. This Privacy Notice applies solely to information collected by NuGrowthRX™.

This Privacy Notice also does not address or apply to, and we are not responsible for, the privacy, information or other practices of any third parties, including, without limitation, the Medical Groups or their Providers, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Services may contain a link. These third parties may at times gather information from or about you. We do not control and are not responsible for the privacy practices of these third parties. We encourage you to review the Medical Groups’ Notice of Privacy Practices, if any, and the privacy policies of each website and application you visit and use.

10. GEOGRAPHIC RESTRICTION

‍Our Services are intended for individuals who are 18 years of age or older and reside in the United States of America. We make no representations that our Services are appropriate or available for use outside of the United States. If you are a resident of another country, or are accessing the website from outside of the United States, please note that you are transferring data to the United States of America which does not have the same data protection laws as the European Union and other regions.

11. CHILDREN’S PRIVACY

‍Our Services are intended for use by individuals who are at least 18 years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Services. If we obtain actual knowledge that we have collected Personal Information through the Site or Mobile App from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such Personal Information or maintaining it in retrievable form. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides is kept secure and that the information submitted is accurate.

12. CONTACT DETAILS

‍For further information regarding this website privacy statement or related NuGrowthRX™ policies and procedures, please contact:
info@nugrowthrx.com

A Group of People LLC
7901 4th St N, Ste 300
St. Petersburg FL 33702