1. Introduction

GlowGuide Inc., a Delaware corporation ("Company," "we," "us," or "our"), respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Med Aesthetics Treatment Tracking and Provider Matching Platform ("Platform").

We are committed to complying with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and maintaining the privacy and security of your protected health information (PHI). This Privacy Policy is designed to align with HIPAA requirements while enabling us to provide you with an optimized service experience.

Please read this Privacy Policy carefully. By using our Platform, you consent to the data practices described in this policy.

2. INFORMATION WE COLLECT

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Create an account and user profile
• Search for and connect with providers
• Track your aesthetic treatments and results
• Communicate with providers through our Platform
• Contact our customer support
• Respond to surveys or participate in promotions

This information may include:

• Name, email address, phone number, and other contact details
• Date of birth and demographic information
• Profile photos and treatment photos
• Treatment history, preferences, and goals
• Communications with providers and our support team

2.2 Protected Health Information (PHI)

As part of our services, we may collect information that constitutes Protected Health Information (PHI) under HIPAA, which may include:

• Medical history related to aesthetic treatments
• Treatment records and results
• Provider notes and recommendations
• Photos documenting treatment results
• Appointment information

2.3 Automatically Collected Information

When you use our Platform, we may automatically collect certain information about your device and usage, including:

• IP address and device identifiers
• Browser type and operating system
• Pages viewed and features used
• Time spent on pages and navigation patterns
• Referral sources and exit pages

This information is collected using cookies, web beacons, and similar technologies. For more information about our use of cookies, please see Section 8 of this Privacy Policy.

3. HOW WE USE YOUR INFORMATION

3.1 Providing and Improving Our Services

We use your information, including PHI, to:

• Create and manage your account
• Match you with appropriate providers
• Track your treatment history and results
• Facilitate communications with providers
• Process and manage appointments
• Respond to your inquiries and provide support
• Improve our Platform functionality and user experience

3.2 Personalization and Recommendations

We use your information, including treatment history, preferences, and platform usage data, to:

• Provide personalized recommendations for treatments and providers
• Offer relevant content based on your aesthetic interests and goals
• Customize your experience on our Platform
• Suggest better matches for your specific needs

3.3 Algorithm Training and Service Enhancement

We use your data to improve our Platform and services in the following ways:

Personalized Recommendations and Matching We process your information to:

• Improve our algorithms designed to match you with the best aesthetic providers
• Deliver personalized treatment recommendations based on your preferences and goals
• Enhance your user experience through relevant content and features

Platform Improvement and Research Similar to other platforms like Airbnb, Netflix, and Spotify, we use aggregated and de-identified data to:

• Train and improve our matching algorithms and recommendation systems
• Develop new features and services that better meet user needs
• Analyze trends and patterns in aesthetic treatments
• Conduct research to improve user outcomes and satisfaction

HIPAA Compliance in Data Processing When using data for these purposes, we implement technical safeguards to de-identify personal information and PHI in accordance with HIPAA standards, including:

• Removing the 18 identifiers specified by HIPAA's de-identification standards
• Ensuring individual users cannot be identified through these processes
• Maintaining appropriate security measures during processing

We process this information given our legitimate interest in improving the Platform services and enhancing your experience. This processing enables us to provide more accurate provider matches and more relevant treatment recommendations.

3.4 Communications

We may use your contact information to:

• Send administrative messages about your account or the Platform
• Provide updates about our services
• Send appointment reminders
• Share marketing communications (subject to your preferences)
• Conduct surveys to improve our services

3.5 Legal Compliance and Protection

We may use your information to:

• Comply with applicable laws and regulations, including HIPAA
• Enforce our Terms of Service
• Protect the rights, safety, and property of our users, providers, and others
• Prevent fraud and abuse of our Platform

4. HOW WE SHARE YOUR INFORMATION

4.1 Sharing with Providers

When you use our Platform to connect with providers:

• We share relevant personal information and PHI with providers you choose to connect with
• This sharing is necessary to facilitate the provider-patient relationship
• Such sharing is covered by HIPAA's permitted uses and disclosures for treatment purposes

4.2 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Hosting and cloud storage providers
• Payment processors
• Customer support services
• Analytics providers
• Email and communication service providers

All service providers that may have access to PHI are bound by appropriate Business Associate Agreements (BAAs) as required by HIPAA.

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Platform of any change in ownership or uses of your information.

4.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). Any such disclosures of PHI will be made in accordance with HIPAA requirements.

4.5 Aggregated and De-identified Data

We may share aggregated, de-identified data that does not identify any individual user with third parties for industry analysis, research, and similar purposes. This information cannot be used to identify you and is not considered PHI under HIPAA.

5. DATA SECURITY

We implement appropriate technical and organizational measures to protect the security, confidentiality, and integrity of your personal information and PHI, including:

• Encryption of data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Employee training on privacy and security practices
• Physical safeguards for our systems and facilities

Despite these efforts, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to protect your information, we cannot guarantee its absolute security.

6. DATA RETENTION

We will retain your personal information and PHI only for as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the information
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the information
• Whether we can achieve those purposes through other means
• Applicable legal and regulatory requirements

7. YOUR RIGHTS AND CHOICES

7.1 HIPAA Rights

As a user whose PHI is protected under HIPAA, you have certain rights, including:

• The right to access your PHI
• The right to request corrections to your PHI
• The right to an accounting of certain disclosures of your PHI
• The right to request restrictions on certain uses and disclosures
• The right to request alternative methods of communication

To exercise these rights, please contact our Privacy Officer at hello@yourglowguide.com.

7.2 Account Information

You can review and update your account information by logging into your account settings on our Platform. If you wish to delete your account, please contact us at hello@yourglowguide.com.

7.3 Marketing Communications

You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in these communications or by contacting us directly.

7.4 Cookies and Tracking Technologies

Most web browsers are set to accept cookies by default. You can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your device. For more information about cookies and how to disable them, please refer to your browser's help menu.

8. COOKIES AND SIMILAR TECHNOLOGIES

8.1 What Are Cookies

Cookies are small data files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to the website owners.

8.2 How We Use Cookies

We use cookies and similar technologies for various purposes, including:

• Essential cookies: Necessary for the Platform to function
• Preference cookies: Enable us to remember your preferences
• Analytics cookies: Help us understand how users interact with our Platform
• Marketing cookies: Used to deliver relevant advertisements

8.3 Your Cookie Choices

You can manage your cookie preferences through your browser settings. However, please note that disabling certain cookies may impact the functionality of our Platform.

9. CHILDREN'S PRIVACY

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information as soon as possible.

10. INTERNATIONAL DATA TRANSFERS

Our Platform is operated in the United States. If you are located outside the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Platform, you consent to this transfer and processing of your information in the United States, which may not provide the same level of data protection as your country of residence.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the revised policy on our Platform with an updated "Last Updated" date. Your continued use of the Platform after such changes constitutes your acceptance of the revised Privacy Policy.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

GlowGuide Inc., a Delaware corporation. hello@yourglowguide.com

By using our Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.