Consumer Health Data Privacy Policy

Roczar Health of America Inc., doing business as DoctorsDirect

Effective Date: July 10, 2026  |  Last Updated: July 11, 2026

This Policy applies to consumer health data as defined by applicable law, including information that identifies or is reasonably linkable to a consumer and reveals past, present, or future physical or mental health status. It should be conspicuously linked on the Platform homepage and at relevant collection points. Where another law provides greater protection, that law controls.

1. Categories of Consumer Health Data

• Health conditions, symptoms, diagnoses, treatments, medications, allergies, and history you provide.
• Healthcare services searched for, requested, booked, purchased, received, or considered.
• Measurements, test results, images, records, and health-related documents uploaded or directed to be shared.
• Location or device information that may reveal an attempt to obtain healthcare services.
• Inferences derived from these categories that relate to health status or healthcare needs.

2. Sources

• You or an authorized representative.
• Providers and provider networks involved in a requested service.
• Business partners through which you access the Platform.
• Devices, browsers, and Platform interactions, subject to permissions and law.
• Service providers acting on our behalf.

3. Purposes of Collection and Use

• Provide, coordinate, and support a product or service you request.
• Authenticate users, process payments, prevent fraud, and maintain security.
• Provide customer support, quality assurance, and complaint resolution.
• Comply with law and establish, exercise, or defend legal claims.
• Other purposes separately disclosed at collection and consented to where required.

DoctorsDirect does not use identifiable consumer health data to train general-purpose AI models or permit third parties to use it for independent model training without separate express consent or another lawful basis. Optional research, sponsor reporting, recording analysis, advertising, or combining data with external sources will use a separate consent where required.

4. Sharing

We may share consumer health data with Providers and provider networks; payment, technology, communications, and support vendors; program sponsors or business partners administering access; professional advisers; governmental authorities where legally required; and parties to a corporate transaction. We share only what is reasonably necessary and impose contractual restrictions where required.

We do not sell consumer health data. We do not share it for targeted advertising without a separate authorization where required by law.

5. Consent and Authorization

When collection or sharing is not necessary to provide a product or service you requested, DoctorsDirect will obtain separate, affirmative consent before the activity where required. The disclosure will identify the categories involved, purpose, categories of recipients, and method of withdrawal. Any future sale of consumer health data would require a separate, valid authorization containing all legally required disclosures and would not be bundled with collection or sharing consent.

6. Your Rights

• Confirm whether we collect, share, or sell consumer health data and access that data.
• Obtain a list of third parties and affiliates with whom consumer health data has been shared or sold, where required.
• Withdraw consent when processing is based on consent.
• Request deletion, including from archives and backups as required and subject to exceptions.
• Appeal a refusal to act on a request.

Submit requests to privacy@doctorsdirect.health. We authenticate requests using commercially reasonable methods and respond within the legally required period. If an appeal is denied, we will provide information about contacting the relevant attorney general where required.

7. Geofencing

DoctorsDirect does not use geofencing around an entity that provides in-person healthcare services to identify or track consumers, collect consumer health data, or send messages or advertisements related to consumer health data where prohibited by law.

8. Retention, Security, and Deletion

We retain consumer health data only as reasonably necessary for the disclosed purpose, service delivery, legal compliance, fraud prevention, dispute resolution, and enforcement. We use reasonable safeguards. Verified deletion requests are implemented as required by law, including downstream notification and deletion from archives or backups where required, subject to lawful exceptions and technical limitations allowed by law.

9. Contact and Changes

Roczar Health of America Inc., doing business as DoctorsDirect
Privacy requests: privacy@doctorsdirect.health
801 Brickell Avenue, Miami, Florida 33131
Telephone: +1 305-677-3786

We may update this Policy prospectively and will provide legally required notice and obtain new consent where a material change requires it.