Privacy Policy

Medici Biologics, Inc. ("Medici Peptides," "we," "our," or "us") respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy explains our policies and procedures regarding the collection, use, disclosure, and security of your personal information, including information by which you may be personally identified.

Medici Peptides provides a web-based telehealth platform that connects patients with licensed healthcare providers for the evaluation, consultation, and management of peptide therapies and other compounded medications. The Platform facilitates online clinical consultations, prescription issuance, and coordination with licensed compounding pharmacies, in accordance with applicable federal and state telehealth and pharmacy laws.

By accessing or using the Medici Peptides Platform (the "Platform"), you accept the practices described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Member Terms of Use that govern your access to and use of the Platform. If you do not agree with our practices, your only choice is to not use the Platform.

This policy applies to information we collect:

• When you access or use the Platform;
• When you register and create an account;
• When you submit a telehealth consultation request or prescription inquiry; and
• Through services provided by third-party companies, agents, or contractors, including our partners.

This policy may change from time to time as described in the "Changes to Our Privacy Policy" section below. To protect your privacy, we limit collection of personal data to what is necessary to provide telehealth and prescription services.

Scope of This Privacy Policy

This Privacy Policy applies to information collected, used, or disclosed in connection with telehealth services made available through the Platform. Certain features may be subject to additional terms, including informed consent documents and telehealth and prescription services terms.

Minors Under the Age of 21

The Platform is not intended for persons under 21. Purchases and subscriptions may only be made by users 21 and older. No person under 13 may use the Platform or provide any personal information under any circumstances, consistent with the Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from children under 13. If you are under 13, do not use the Platform or provide any information about yourself to us. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will delete it promptly. If you believe we may have information from or about a child under 13, please contact us at legal@medicipeptides.com.

Information We Collect About You and How We Collect It

We collect or may collect the following types of information from members who access and use the Platform:

• Identity and contact information: name, username, date of birth, email address, and phone number;
• Clinical and health information: symptoms, medical history, current medications, allergies, and other clinical information you provide during a consultation; prescription orders issued by licensed providers; and records of peptide therapies or compounded medications dispensed through our pharmacy partners;
• Personal demographics used to determine clinical eligibility and support prescription decisions: age, weight, height, and sex at birth. An encrypted payload containing relevant data is generated and transmitted to our secure cloud environment;
• Payment information: billing name, address, and payment card details necessary to process subscription and service fees. Payment card data is collected and processed directly by our PCI-compliant third-party payment processor and is not stored on our servers;
• Device and technical data: hardware model, operating system version, IP address, browser type and version, and cookie identifiers;
• Correspondence: records and copies of any communications if you contact us or report a problem; and
• Analytics data: usage patterns, session information, and other data collected automatically as you navigate the Platform.

We collect this information:

• Directly from you when you provide it;
• Automatically as you navigate the Platform; and
• Through cookies, web beacons, and similar tracking technologies.

Data Minimization

We take every reasonable step to limit the volume of personal information we process to what is reasonably necessary to provide telehealth and prescription services. We do not store unnecessary biometric data, and sensitive health information is handled in accordance with HIPAA and applicable state law.

Consequences of Not Providing Personal Information

If you do not provide certain personal information, we may not be able to provide you access to the Platform or the support we otherwise could. In the context of telehealth services, failure to provide complete and accurate health and identity information may prevent a licensed provider from issuing a valid prescription.

Third-Party Service Providers

We may partner with third-party companies, agents, or contractors ("Service Providers") for various purposes, including licensed compounding pharmacies, licensed healthcare providers, prescription management systems, electronic health record platforms, payment processors, and marketing and analytics providers. Service Providers may have access to your information as necessary to perform their functions. We do not authorize Service Providers to use or disclose your information except as necessary to perform services on our behalf or as required by law.

Service Providers may have their own privacy policies. You should review those policies if you wish to understand how they handle your information. We do not publish a current list of Service Providers, but you may request it by emailing legal@medicipeptides.com.

How We Use Your Information

We use your information only when applicable law allows us to do so. We will generally use your information:

• Where necessary to provide the Platform and related services;
• Where necessary for our legitimate business interests or those of a third party;
• Where required to comply with a legal or regulatory obligation; or
• Where you have given your consent (which can be withdrawn at any time).

Specifically, we use your information to:

• Provide the Platform, including facilitating telehealth consultations and prescription processing;
• Verify your identity and prevent fraud or unauthorized activity;
• Manage your subscription, send billing reminders, and notify you of subscription-related changes or renewals;
• Enable Service Providers to perform services in connection with the Platform;
• Notify you about changes to the Platform;
• Enhance the safety and security of the Platform;
• Estimate audience size and better understand usage patterns;
• Provide technical and other support; and
• Fulfill any other purpose for which you provide it or to which you consent.

We may use health information, where applicable, to support telehealth consultations, treatment recommendations, and prescribing activity, solely in accordance with applicable law and subject to appropriate privacy and security safeguards.

Storage and Transfer of Your Information

We may store information that we collect in databases and servers owned and maintained by us, our affiliates, or Service Providers. If you access the Platform outside of the United States, information we collect about you may be transferred to and maintained on servers inside the United States. By using the Platform, you consent to such transfer and processing.

We do not store payment card numbers on our servers. Full card data is handled exclusively by our PCI-compliant payment processor. Health information and prescription records are retained in accordance with applicable HIPAA and state medical records retention requirements.

Disclosure of Your Information

We will never sell your personal information.

We may disclose personal information:

• To our subsidiaries and affiliates;
• To Service Providers, but only to the extent necessary for them to provide services on our behalf;
• To licensed healthcare providers, compounding pharmacies, and pharmacy benefit managers as necessary to fulfill a prescription or provide telehealth services;
• To a potential or actual buyer or successor in the event of a merger, acquisition, restructuring, dissolution, or similar transaction;
• To fulfill the purpose for which you provided the information; and
• With your consent.

We may also disclose your information:

• To comply with any court order, law, or legal process, including government or regulatory requests;
• To enforce the Member Terms of Use and other agreements, including for billing and collection; and
• If we believe disclosure is necessary to protect the rights, property, or safety of Medici Peptides, our members, or others.

We comply with all applicable state and federal laws governing the privacy and confidentiality of member records, including HIPAA, the Privacy and Security Standards (45 C.F.R. Parts 160 and 164), and the HITECH Act. We additionally comply with applicable state telehealth practice standards, pharmacy laws, and controlled substance regulations. We will not disclose your medical records or other member information to any third party except where required or permitted by law and any applicable business associate agreement.

Use of Artificial Intelligence

Medici Peptides operates as a HIPAA-covered entity and/or business associate, as applicable, in connection with providing the Platform. We use artificial intelligence to generate educational health insights, wellness guidance, and treatment information within the Platform. AI features support - but do not replace - clinical decision-making by licensed providers.

When AI features are used, inputs may be processed through secure third-party AI infrastructure. We evaluate and select AI providers based on their compliance with HIPAA and applicable data security standards. Before any information is transmitted for AI processing:

• Personal identifiers are removed;
• Data is de-identified within our secure environment; and
• Only the minimum information necessary to generate a response is transmitted.

Our platform infrastructure is designed to align with HIPAA and SOC 2 security standards. AI responses are provided for informational and educational purposes only and should not be considered medical advice.

Telehealth Services and Prescription Processing

Medici Peptides facilitates the provision of telehealth services by independent, licensed healthcare providers. In connection with these services, we may collect, use, and share health information as necessary to:

• Conduct an online consultation and evaluate your eligibility for prescribed therapies;
• Issue and transmit prescriptions to licensed compounding pharmacies;
• Coordinate dispensing, shipping, and follow-up care with pharmacy partners; and
• Maintain records in accordance with applicable medical records laws.

Licensed healthcare providers operating through the Platform are independent professionals and may be subject to their own privacy obligations. Prescriptions and related records are treated as protected health information ("PHI") under HIPAA.

Subscriptions and Billing

Medici Peptides offers subscription plans that provide access to ongoing telehealth consultations and prescription management services. Subscriptions are billed on a recurring basis and will automatically renew unless canceled at least 24 hours before the renewal date. You can manage and cancel your subscription through your account settings at www.medicipeptides.com or by contacting us at legal@medicipeptides.com.

We process payments through a PCI-compliant third-party payment processor. We do not store full payment card numbers on our systems. Refund eligibility is governed by the Member Terms of Use.

Anonymized or Aggregated Information

We may share information that is anonymized or aggregated in a form that does not include any personal information about you. We may use, disclose, or share anonymized or aggregated information for any purpose without restriction, so long as it does not violate this Privacy Policy or applicable law.

Accessing and Correcting Your Personal Information

You may change, correct, or delete personal information that you have provided to us through your account or by emailing us at legal@medicipeptides.com.

Your California Privacy Rights

California Civil Code §1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at legal@medicipeptides.com or by mail at Medici Biologics, Inc., 4330 Gaines Ranch Loop, Suite 230, Austin, TX 78735.

California residents may also have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know, delete, and opt out of the sale of personal information. We do not sell personal information. For questions about your California privacy rights, please contact us at legal@medicipeptides.com.

How Long We Store Your Personal Information

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required to satisfy legal, accounting, or reporting requirements, resolve disputes, or enforce our agreements. Medical and prescription records will be retained for the minimum period required by applicable state and federal law, which may be longer than our general data retention period. Upon request, we will delete your personal information, subject to applicable legal retention obligations. Data may persist in backup copies for additional time.

Information Security

We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, no security controls are 100% effective, and we cannot guarantee the security of your information. Any transmission of personal information is at your own risk.

The security of your account also depends on you. You are responsible for maintaining the confidentiality of your account credentials. Please use a strong, unique password and do not share your login information with anyone. Notify us immediately at legal@medicipeptides.com of any unauthorized access to your account.

Changes to Our Privacy Policy

If we make material changes to how we treat your personal information that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by email to the address in your account and/or through a notice on the Platform. Your continued use of the Platform after such changes constitutes your agreement to the revised policy. You are responsible for ensuring that we have a current, deliverable email address for you.

Survival

The policies set out in this Privacy Policy remain effective even if the Member Terms of Use or other agreements between us are terminated and you are no longer using the Platform.

Contact Information

To ask questions or comment about this Privacy Policy, or to exercise any privacy rights you may have, please contact us:

Medici Biologics, Inc. dba Medici Peptides Medici Biologics, Inc., 4330 Gaines Ranch Loop, Suite 230, Austin, TX 78735 Email: legal@medicipeptides.com • Website: www.medicipeptides.com