Privacy Policy

1. Scope and our role

Sinta provides technology and non-medical administrative services that help wellness businesses and consumers connect with independent healthcare providers and supporting services.

Sinta does not practice medicine, provide medical care, prescribe medication, or make clinical decisions.

Medical and clinical services available through the Services are provided independently by third-party clinical organizations and their licensed healthcare providers. Beluga Health, P.A. is responsible for all medical consultations available through Sinta. Pharmacy fulfillment is provided by Beluga's approved pharmacy partners, which independently dispense prescribed medications. Junction's network physicians approve and review laboratory orders handled through their network; their responsibility is limited to laboratory orders approved by that network and does not extend to other laboratory orders. Laboratory services are performed by independent laboratories. Sinta provides technology and non-medical administrative support; it does not provide medical consultations or dispense medications.

Participating wellness businesses (“Partners”) may provide separate Partner Wellness Services to their clients. Depending on the Partner and applicable law, these may include wellness education, lifestyle guidance and support, general nutritional guidance, fitness or wellness support, accountability, progress tracking, regular check-ins, and other wellness services.

Partner Wellness Services are separate from the medical and clinical services provided by licensed healthcare providers.

2. Information we collect

Information you provide

We may collect information you provide directly, including:

• Contact and identity information, such as your name, email address, telephone number, mailing address, and date of birth;
• Account information, login credentials, preferences, and communications with our support team;
• Health and wellness information, medical history, treatment interests, medications, allergies, symptoms, health goals, and other information submitted through the Services;
• Payment, billing, transaction, and related information necessary to facilitate payments and transactions;
• Information provided through forms, questionnaires, intake processes, program enrollment, appointments, communications, and other interactions with the Services; and
• Other information you voluntarily provide.

Information collected automatically

When you use the Services, we may automatically collect certain information about your device and use of the Services, including IP address, browser type, device information, operating system, referring pages, pages viewed, dates and times of access, approximate location derived from IP address, and interactions with the Services.

Our public website may include embedded forms, chat features, and similar communications tools supplied by service providers. When you use those tools, the provider may process the information you submit together with device, cookie, and interaction information on Sinta's behalf.

Information from other sources

We may receive information from Beluga Health, P.A. and its licensed healthcare providers, Junction and its network physicians for laboratory orders approved by that network, participating Partners and their authorized personnel, pharmacies, laboratories, payment processors, fulfillment providers, technology vendors, and other service providers involved in providing or supporting the Services.

Information received from Partners may include information relating to Partner Wellness Services, client engagement, wellness support, accountability, progress tracking, and other authorized interactions with their clients.

Information in different workflows

References to Beluga Health in this policy mean Beluga Health, P.A. Information collected for medical intake and consultations, Partner Wellness Services, payment administration, and public website inquiries serves different purposes. Collection and access depend on the service involved, the recipient's role, applicable permissions, and applicable law. A public website inquiry does not itself authorize a Partner to access your clinical records.

3. How we use information

We use information as reasonably necessary to:

• Provide, maintain, operate, and improve the Services;
• Create and administer accounts and verify user identity;
• Facilitate consumer intake and connect consumers with Beluga Health, P.A. and its licensed healthcare providers for independent medical evaluation and clinical services;
• Coordinate program status, appointments, laboratory services, pharmacy workflows, fulfillment, and other administrative aspects of the Services;
• Support authorized Partner Wellness Services, client engagement, wellness education, lifestyle support, accountability, and progress tracking;
• Where enabled, use AI-assisted tools to help create educational summaries, scores, trends, and draft wellness insights. These tools support informational and administrative functions and are not used by Sinta to diagnose, prescribe, determine medical eligibility, or make other clinical decisions. We do not use identifiable patient information to train general-purpose AI models for Sinta, and any service provider that processes such information must do so under applicable contractual, privacy, and security requirements;
• Process and facilitate payments, transactions, Partner Settlements, refunds, reversals, and related financial administration;
• Provide customer support and respond to requests;
• Maintain platform security, detect and prevent fraud, troubleshoot technical issues, and protect users and the Services;
• Send service-related communications and, where permitted, marketing or promotional communications;
• Comply with legal, regulatory, contractual, recordkeeping, and compliance obligations; and
• Create aggregated or de-identified information that cannot reasonably be linked to an identifiable individual.

Sinta does not use consumer health information to make medical eligibility, diagnosis, treatment, prescribing, dosage, or other clinical decisions. Those clinical decisions are made independently by licensed healthcare providers.

AI-assisted tools

Where enabled and permitted for the relevant service, authorized AI service providers may process identifiable patient information to provide educational summaries, trends, and draft wellness insights on Sinta's behalf. This processing remains subject to the privacy, security, contractual, and authorization requirements that apply to that information, including a Business Associate Agreement where required. Sinta does not use these tools to make clinical decisions.

4. How we share information

We may share information only as reasonably necessary with:

• Beluga Health, P.A. and its licensed healthcare providers, as necessary to provide medical evaluation, treatment, prescribing, clinical follow-up, and related healthcare services;
• Junction and its network physicians, as necessary to approve and review laboratory orders handled through and approved by that physician network;
• Independent pharmacies, laboratories, and fulfillment providers involved in services requested or authorized through the platform;
• Participating Partners and their authorized personnel, where permitted by applicable law, appropriate authorization or consent, and applicable agreements, and only to the extent reasonably necessary to support authorized Partner Wellness Services, client engagement, program administration, or other permitted functions;
• Vendors and service providers that support hosting, infrastructure, security, communications, embedded forms and chat, identity verification, customer support, payment processing, analytics, AI-assisted functionality, platform functionality, and other operational functions;
• Professional advisers, insurers, auditors, accountants, attorneys, and similar parties where reasonably necessary;
• Government authorities, regulators, law enforcement, courts, or other parties when required by law or reasonably necessary to protect users, Sinta, the Services, or legal rights; and
• A successor or acquiring entity in connection with a merger, financing, acquisition, reorganization, sale of assets, or similar business transaction, subject to applicable law.

Partners do not receive unrestricted access to a consumer's health or clinical information merely because the consumer accesses the Services through that Partner.

Partner access may be limited based on the Partner's role, authorization, permitted purpose, applicable agreements, and applicable law. Access to clinical information may be further restricted according to the Partner's role and authorization.

Sinta does not sell consumer health data. Sinta also does not sell personal information or share personal information for cross-context behavioral advertising as those terms are defined by applicable privacy law.

We do not use consumer health data for targeted advertising or permit service providers to use consumer health data for their own advertising purposes.

Where applicable law requires consent or authorization before information is disclosed, we will obtain the required consent or authorization.

Access follows the service

Beluga Health, P.A. and its licensed providers receive information needed for consultations and clinical services. Beluga's approved pharmacy partners receive information needed for authorized pharmacy fulfillment. Junction and its network physicians receive information needed to approve and review laboratory orders approved by that network. Partners receive only information permitted for their authorized wellness and administrative functions. Payment and technology service providers receive information needed for their permitted functions, subject to applicable law and agreements. These arrangements do not give Partners unrestricted access to clinical records.

5. Communications and SMS

We may send transactional and service-related communications regarding your account, appointments, program activity, orders, security, and use of the Services.

If you separately consent to receive marketing or promotional communications, we may send those communications as permitted by applicable law.

If you provide a mobile telephone number and consent to receive text messages, message and data rates may apply. Message frequency may vary.

You may opt out of nonessential text messages by following the instructions provided in the message, such as replying STOP where applicable.

Opting out of marketing or promotional communications does not prevent us from sending communications that are necessary to administer your account, provide requested Services, communicate important safety or security information, or satisfy legal obligations.

Text messaging and your choices

Consent to marketing text messages is separate from acceptance of our Terms and is not a condition of purchasing services. We do not sell or share mobile telephone numbers or text-message consent with third parties for their own marketing. We may provide this information to service providers that help deliver and administer messages on our behalf, subject to applicable restrictions.

You may revoke consent to text messages by replying STOP or through another reasonable method, including contacting us through our contact form or calling (561) 475-1218. Reply HELP for messaging assistance. We will honor valid revocation requests as required by applicable law.

Necessary service communications do not override a valid revocation of consent to text messages. Where appropriate and authorized, necessary communications may instead be provided through another permitted channel, subject to applicable law. Text messaging is not a secure channel for sending medical records or other sensitive health information.

See our Terms and Conditions — Communications and SMS for additional messaging terms.

6. Cookies and analytics

We and service providers acting on our behalf may use cookies and similar technologies to operate the Services, remember preferences, maintain security, support embedded forms and chat, understand how users interact with the Services, and improve performance.

These technologies may collect device identifiers, IP address, browser information, referring pages, pages viewed, dates and times of access, and interactions with website features. We do not permit service providers to use consumer health data collected through the Services for their own advertising purposes.

Where required by applicable law, we will request consent before using nonessential cookies or similar technologies.

You may be able to control cookies through your browser settings, consent tools made available through the Services, or legally recognized opt-out preference signals where applicable. Disabling certain cookies may affect the functionality of the Services.

7. Retention and security

We retain personal information only for as long as reasonably necessary for the purposes described in this policy and to satisfy applicable legal, contractual, security, recordkeeping, dispute-resolution, and operational obligations. The criteria we use include:

• Account and profile information: for the duration of the account and a reasonable period afterward to administer closure, prevent fraud, resolve disputes, and meet legal obligations;
• Transaction and payment information: for periods required by payment processors and applicable accounting, tax, fraud-prevention, and recordkeeping requirements;
• Health and wellness information: for the period permitted or required by applicable law, authorization, contractual obligations, and the healthcare or wellness workflow involved;
• Support and communications records: for as long as reasonably necessary to address the request, document the interaction, improve support, and protect legal rights; and
• Website and technical information: for the period reasonably necessary for security, troubleshooting, analytics, and performance purposes, unless a longer period is required by law or needed to investigate misuse.

We use administrative, technical, and physical safeguards designed to protect information against unauthorized access, use, alteration, loss, or disclosure.

No method of electronic transmission or storage can be guaranteed to be completely secure.

If a privacy or security incident occurs, we will investigate and provide notices to affected individuals, healthcare organizations, regulators, or other parties as required by applicable law and applicable agreements.

Information maintained independently by Beluga Health, P.A., Junction or its network physicians, other licensed healthcare providers, pharmacies, laboratories, Partners, or other third parties may be subject to their own legal, professional, contractual, and record-retention obligations.

8. Your rights and choices

Depending on where you live and the applicable law, you may have the right to:

• Confirm whether we process your personal information and request access to it;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to legal and operational exceptions;
• Receive a portable copy of eligible personal information;
• Withdraw certain consents or authorizations for future processing;
• Opt out of certain sale, sharing, targeted advertising, or profiling activities if Sinta engages in an activity for which applicable law provides an opt-out right; and
• Appeal a decision concerning a privacy request where applicable law provides that right.

Requests relating specifically to consumer health data may also be governed by our Consumer Health Data Privacy Policy.

Some health or clinical information may be maintained independently by Beluga Health, P.A., Junction or its network physicians, other licensed healthcare providers, pharmacies, laboratories, or other healthcare organizations. Requests relating to records maintained by those organizations may need to be directed to the applicable organization.

To make a privacy request, use our contact form or call (561) 475-1218. We may request information reasonably necessary to verify your identity and authority to make the request. Where permitted by law, an authorized agent may submit a request on your behalf, but we may require proof of the agent's authority and verification directly from you.

If we deny a request, you may appeal by replying to the decision or submitting a new message labeled “Privacy Appeal.” We will not discriminate against you for exercising a privacy right.

Help with healthcare records

If your request concerns records maintained by Beluga Health, P.A., Junction or its network physicians, a pharmacy, or a laboratory, contact the responsible organization using its privacy notice or patient portal. You may also ask Sinta for help identifying the appropriate contact. Sinta cannot independently change or delete records maintained by another organization, and applicable retention requirements may limit deletion.

When contacting Sinta through the public contact form, describe the type of privacy assistance you need without including medical records, detailed health information, payment card information, or identity documents. We will explain any appropriate verification steps and secure method needed to handle your request.

9. Additional U.S. state disclosures

Some U.S. state privacy laws require additional information about categories of personal information, sources, purposes, and recipients. Sections 2 through 4 of this policy describe those practices in detail. Depending on the law that applies to you, health information, account credentials, precise geolocation, financial information, and other data may be treated as sensitive personal information and receive additional protections.

Sinta does not sell personal information or share personal information for cross-context behavioral advertising. If our practices change, we will update this policy and provide any legally required opt-out mechanism before engaging in the new activity.

We will process legally recognized opt-out preference signals, such as the Global Privacy Control, when required by applicable law and relevant to our data practices.

10. Additional information

Children

The public website and consumer self-enrollment portions of the Services are intended for adults and are not directed to individuals under 18. We do not knowingly collect personal information from children through Services intended exclusively for adults. If a service expressly permits a minor to participate, the service must use an authorized parent or guardian process and comply with applicable law and the requirements of the responsible healthcare provider.

Third-party services

The Services may link to or integrate with third-party websites, applications, healthcare providers, pharmacies, laboratories, payment processors, and other services. Their privacy practices are governed by their own privacy notices and policies.

Changes to this policy

We may update this policy as our Services, technology, partners, or legal obligations change.

We will post the revised policy with a new “Last updated” date and provide additional notice or obtain consent when required by applicable law.