Privacy Policy

1. Introduction

GetTrueCare Enterprises Inc, doing business as Prestige Wellness Company (“Prestige Wellness,” “we,” “us,” or “our”), is a Wyoming corporation operating a B2B healthcare technology platform and group purchasing organization (GPO). We are committed to protecting the privacy and security of information provided to us by our clients and website visitors.

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at prestigewellnesscompany.com or interact with our platform and services. Please read this policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

Important: Prestige Wellness serves licensed medical clinics and practices, not individual patients. If you are a patient, your healthcare provider and the dispensing pharmacy are the appropriate parties to contact regarding your personal health information. Prestige Wellness does not directly collect patient health information.

2. Information We Collect

We collect several categories of information in connection with operating the Prestige Wellness Platform and website, described in detail below.

2.1 Information from Clinic Representatives and Prescribers

When a clinic or prescriber registers for, applies to access, or uses the Prestige Wellness Platform, we may collect:

• Business and clinic information: clinic legal name, DBA, address, phone number, email address, tax identification number (EIN), state business registration, and clinic licensure information.
• Authorized representative information: name, title, email address, phone number, and signature.
• Prescriber credentials: name, NPI number, state medical license number(s) and jurisdiction(s), DEA registration number (where applicable), specialty, and credential type.
• Identity verification data: government-issued ID (front and back) and real-time selfie captured during the identity verification process. This data is processed by a third-party identity verification provider and is used solely for verification purposes.
• OIG exclusion screening data: information used to conduct OIG LEIE and SAM.gov exclusion screenings, including name, NPI, and address.
• Payment authorization information: credit card or bank account details provided in connection with payment authorization. Payment processing is handled by PCI DSS-compliant payment processors. Prestige Wellness does not store full payment card numbers.
• Order information: medication orders submitted through the Platform, including prescriber identity, medication type, and shipping destination. Orders do not include patient health information stored by Prestige Wellness.

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain information including:

• Device and browser information: IP address, browser type and version, operating system, device type, and unique device identifiers.
• Usage data: pages visited, time spent on pages, links clicked, referring URLs, and navigation patterns.
• Cookie data: see Section 7 (Cookies and Tracking Technologies) below.

2.3 Information You Provide Directly

We collect information you provide when you contact us, request a consultation, complete intake forms, respond to communications, or otherwise interact with us directly.

3. How We Use Information

We use the information we collect for the following purposes:

• Platform onboarding and account management: verifying clinic and prescriber credentials, establishing Platform access, and managing ongoing account relationships.
• Compliance and credentialing: conducting primary source license verification, OIG exclusion screening, identity verification, and ongoing compliance monitoring as required by our platform policies.
• Order processing and fulfillment: routing orders to the appropriate dispensing pharmacy in the Prestige Wellness Pharmacy Network.
• Payment processing: collecting and processing fees in connection with Platform use.
• Communications: sending account-related communications, compliance updates, platform notifications, and marketing communications to authorized clinic contacts who have opted in.
• Legal compliance: complying with applicable federal and state laws, regulations, and legal process.
• Platform improvement: analyzing usage data to improve the functionality, security, and user experience of the Platform.
• Security: detecting, investigating, and preventing fraudulent transactions, unauthorized access, and other prohibited activities.

4. HIPAA and Protected Health Information

Prestige Wellness is a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations. We enter into a Business Associate Agreement (BAA) with each Participating Clinic prior to platform access.

Prestige Wellness does not directly collect, store, or process Protected Health Information (PHI) from patients. Order submissions through the Platform may include patient shipping addresses and medication information, which are transmitted directly to the dispensing pharmacy. The clinic and the dispensing pharmacy are the primary HIPAA Covered Entities responsible for patient PHI.

Any information that constitutes PHI under HIPAA is handled in accordance with our Business Associate Agreement and applicable HIPAA regulations. We do not use or disclose PHI except as permitted by our BAA and applicable law.

5. Information Sharing and Disclosure

We do not sell, trade, or rent personal information to third parties. We may share information in the following circumstances:

• Pharmacy Network Partners: Order information is transmitted to the licensed 503A compounding pharmacy designated to fulfill the order. Each pharmacy partner is independently responsible for handling information in accordance with applicable laws and their own privacy policies.
• Payment Processors: Payment information is shared with our PCI DSS-compliant payment processors for the purpose of processing transactions. Payment processors are contractually prohibited from using payment information for any other purpose.
• Identity Verification Provider: Government-issued ID and selfie data is shared with our third-party identity verification provider solely for the purpose of verifying prescriber identity. This data is not retained by Prestige Wellness.
• Service Providers: We may share information with third-party service providers who assist in operating our platform, conducting business, or servicing clients, provided those parties agree to keep information confidential and use it only for the purposes disclosed.
• Legal Compliance: We may disclose information when required by applicable law, court order, subpoena, or governmental authority, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, information may be transferred as part of that transaction, subject to standard confidentiality protections.

6. Data Security

We implement commercially reasonable technical and organizational measures to protect the information we collect and maintain. These measures include encryption of data in transit, access controls, authentication requirements, and regular security assessments.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach that requires notification under applicable law, we will notify affected parties in accordance with our legal obligations.

7. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. Please see our separate Cookie Policy at prestigewellnesscompany.com/cookie-policy for detailed information about the cookies we use, their purpose, and how to manage your cookie preferences.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Credential and compliance documentation for active clinic accounts is retained for the duration of the account relationship plus a minimum of seven (7) years or as otherwise required by applicable law.

Identity verification data is retained only as long as necessary for the verification process and is then deleted from Prestige Wellness systems. We cannot control the retention practices of our third-party identity verification provider.

9. Your Privacy Rights

Depending on your location, you may have certain rights regarding the personal information we hold about you, as described below.

9.1 California Residents (CCPA)

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to request deletion of personal information, and the right to opt out of the sale of personal information (we do not sell personal information). To exercise your California privacy rights, contact us at accounts@prestigewellness.com.

9.2 All Users

Regardless of your location, you may request access to, correction of, or deletion of your personal information by contacting us at the information below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

10. Third-Party Links

Our website may contain links to third-party websites and services. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children’s Privacy

Our platform and services are directed solely at licensed medical professionals and clinic entities. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor, we will promptly delete it.

12. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will notify registered Platform users of material changes via email or Platform notification. The “Last Updated” date at the top of this policy reflects the most recent revision. Continued use of our website or Platform following notice of changes constitutes acceptance of the updated policy.

13. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact: