PRIVACY POLICY

Last updated: 2/3/26

LucyRx and its applicable affiliated companies (collectively, “LucyRx”, “we”, “us”, or “our”) is committed to respecting your privacy.  This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that you (“you” or “user”) may provide to us through your use of our website located at www.LucyRx.com, and any other websites that we link to this Privacy Policy (collectively, our “Website”) our mobile application(s) (the “App”), and any services, applications, software, features, content, websites and/or linked pages, offered from time to time by us in connection therewith, and any other product or service that links to these Terms of Use (collectively, the “Services”).

NOTE: If you are a member of a health plan that has contracted with LucyRx to provide pharmacy benefit services and are using our Website or App or otherwise interacting with us in your capacity as a member, all protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”) and “health information” under state law, that we create or that we receive in connection with your health care, is governed by HIPAA.  For this health information, the content of your health plan’s HIPAA Notice of Privacy Practices applies to your use of our Services.  You can ask your health plan for a copy of its HIPAA Notice of Privacy Practices.

Additionally, if you have entered into a separate agreement with us, that separate agreement shall control, and only those terms within this Privacy Policy that do not conflict with such separate agreement shall apply.  This Privacy Policy does not cover information we receive from or process on behalf of third parties, including health plans.

By accessing the Services, you agree to be bound by this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use the Services.  Each time you use the Services, the current version of this Privacy Policy will apply. Accordingly, when you use the Services, you should check the date of this Privacy Policy (which appears at the top) and review any changes since you last reviewed the Privacy Policy.

If you have any questions regarding this Privacy Policy, please contact us at privacy@lucyrx.com.

INFORMATION WE COLLECT

We collect two types of information from users of our Services: “Personal Information,” which is information that you provide that can be used to identify you (such as your name or your email address), and “Aggregate Information,” which is information that cannot be used to identify you (such as frequency of visits to the Services and your browser type).

INFORMATION YOU PROVIDE TO US

We collect Personal Information that you voluntarily provide to us when you use our Services.  For example, you may provide us with your contact information such as your email address, first and last name, employment related information, the content of your communication, or other Personal Information when you choose to submit such information to us through email, an online form, or other method.  When you download or access digital resources, we also collect similar contact information from you.  If you interact with us on social media, we may collect your social media profile information, your communications with us, and your communications and posts on our social media pages.

If you create an account in the Services, you may provide certain information directly to us for purposes of creating an account.  You may also provide information related to others, however, please do not provide any information to us that you do not have permission to provide.

NOTE: Please do not submit any information that is considered PHI under HIPAA or “health information” under state law through any general inquiry or comment function on our Services.

INFORMATION WE AUTOMATICALLY COLLECT 

When you use our Services, we automatically receive and collect information from your device.  This information includes the following:

• Information about your device, such as the operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language.
• The specific actions that you take when you use our Services, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Services.
• The time, frequency, connection type, and duration of your use of our Services.
• Information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.
• Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
• Pages you visited before or after navigating to our Services.

GEOLOCATION

With your permission, or if your device’s location settings are enabled to allow our App to collect this data, we may collect precise geolocation data, such as the global position system or GPS location, of your device.

EMPLOYMENT

If we have collected your Personal Information through our “Careers” page or email in response to a job opening, you are giving us permission to use and retain your Personal Information for the purpose of evaluating your application for employment consideration for the specific position that you applied to, as well as other roles at LucyRx.  This Personal Information may be processed and stored by a third-party talent tracking solution provider as well as with vendors, consultants, and other service providers who need access to such information to carry out work relating to the recruitment process on our behalf.

AGGREGATE INFORMATION COLLECTED

Aggregate Information is information that does not identify you.  Aggregate Information may be collected when you use our Services, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains.  We may collect, use, store, and transfer Aggregate Information without restriction.

COOKIES, ANALYTICS, AND OTHER TRACKING TECHNOLOGIES

Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser to help us identify you when you come to our Website. Like many websites, we use cookies on our Website. We use cookies to power and improve our Website and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use cookies on our Website to better tailor the Services, products and advertising on our Website and other websites.

Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies through your browser controls. Please keep in mind that removing or blocking cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking cookies may not completely prevent how we share information with third parties such as our advertising partners.

We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our Website. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google here. You may find additional information about Google Analytics here. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page.

We also permit third parties and service providers to use online tracking technologies on our Website for advertising and data enrichment purposes, including to help manage and display advertisements, to tailor advertisements to your interests, or to send you reminders and notifications (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear on our Website, on other websites, or in our email communications. These technologies may also use tracking codes to identify you by your device information or internet protocol, or IP address, by connecting such information to information available from other sources, which may include your contact information and other personal information.  To the extent these online tracking technologies are considered to be a “sale” or “sharing” of personal information (which includes targeted advertising, as defined under the applicable laws) under applicable privacy laws, you can opt-out of these online tracking technologies by adjusting privacy settings in your browser and on your devices, or following the instructions provided in this Privacy Policy.

We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Website or social media and whether or not certain content, such as a video was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Policy.

At the present time our Website does not respond to “Do Not Track” signals or similar mechanisms.

INTEREST-BASED ADVERTISING

We may also participate in interest-based advertising.  This means that you may see advertising on our Website tailored to how you browse, or you may see advertising for LucyRX on other websites based on your browsing behavior across websites.  Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for LucyRX.  Other websites where you see our ads may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.

You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website.

How We Use Your Information

In general, we collect information and Personal Information from you so that we can provide our Services, operate our business, and provide information that you request from us.  This includes but is not limited to the following, and will depend on the nature of your relationship with us:

• Provide, operate, improve, maintain, and protect our Services.
• Create and administer your account.
• Provide you with technical and other support.
• Send you updates, marketing communications, and other information about LucyRx and our Services.
• Send you notices and alerts.
• Conduct research, analytics, and monitor and analyze trends and usage.
• Contact you and respond to your inquiries.
• Enhance or improve user experience, our business, and our Services, including the safety and security thereof.
• Personalize our Services to you.
• As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
• Enforce contracts, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of LucyRx, our users, or the public as required or permitted by law.

How We Share Your Information

We do not rent or sell your Personal Information.

Like most companies, we share information, including Personal Information, in certain circumstances with third parties through operation of our Services and our business.  Below we explain when that happens.

SERVICE PROVIDERS

We may transfer Personal Information to third parties for the purpose of providing the Services or operating our business.  For example, we may transfer your Personal Information to third-party service providers to assist with providing the Services, and to communicate with you about current or future offerings.

REQUIRED TRANSFERS

We may also transfer your Personal Information to third parties under the following circumstances: (i) to comply with a legal requirement, law, subpoena, judicial proceeding, court order, governmental request, or legal process; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation or dissolution of LucyRx, including the evaluation thereof; (iv) when we believe it is necessary to protect the rights, property, or safety of LucyRx or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of LucyRx.

AS DIRECTED BY YOU AND WITH YOUR CONSENT

Except as otherwise provided in this Privacy Policy, we share Personal Information with companies, organizations or individuals outside of LucyRx only at your direction or when we have your consent to do so.

State Privacy Rights and Disclosures

We strive to provide you with choices with respect to your Personal Information.  Also, remember, you can opt not to disclose certain information to us – but keep in mind some information may be needed to create an account or to take advantage of some of the features of our Services.

In accordance with applicable law, you may exercise the rights described in this section. Please note that some of the rights may vary depending on your state of residence.

In accordance with applicable law, you may exercise the rights described in this section. Please note that some of the rights may vary depending on your country or state of residence.

The Right to Opt-Out of Cookies and Sale/Sharing Using Online Tracking Technologies

Our use of certain online tracking technologies may be considered a “sale” / “sharing” under applicable privacy laws. Website visitors can opt out of being tracked by these third parties by clicking the “Your Privacy Choices” link at the bottom of our Website and selecting their preferences.

You may opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Categories of Personal Information disclosed that may be considered “sale” / “sharing”: Unique Identifiers, Demographics, Commercial Information, Internet or Other Electronic Activity, and Inferences Drawn from Other Categories to Create a Profile.

Categories of third parties to whom Personal Information was disclosed that may be considered “sale”/ “sharing” include advertisers and marketing partners, and analytics providers.

If you are a Nevada resident, you have the right to request that a company not sell your Personal Information for monetary consideration to certain other parties. This right applies even if your Personal Information is not currently being sold. To make such request, please send an email to privacy@lucyrx.com with “Nevada Opt-Out of Sale” in the subject line and in the body of your message. We will provide the requested information to you via an email response.

The Right to Limit the Use and Disclosure of Sensitive Personal Information

We only collect sensitive Personal Information, as defined by applicable privacy laws for the purposes allowed by law or with your consent. We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about you. Therefore, we do not offer the right to limit the use of sensitive Personal Information.

The Right to Access, Correct, and Delete Personal Information

You may have the right to request access to and receive details about the Personal Information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your Personal Information. You may also have the right to withdraw your consent to our processing of your Personal Information. These rights may be limited in some circumstances by applicable law.

Access and Deletion You can submit a request to access or delete your Personal Information, or withdraw consent, by:

• Call 559-312-2808; or
• Emailing privacy@lucyrx.com.

Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by applicable law. Please note that in many situations we must retain all, or a portion, of your Personal Information in order to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for another one of our business purposes.

Corrections: You can correct information by:

• 559-312-2808; or
• Emailing privacy@lucyrx.com.

You may submit a request for a copy of the information collected about you by following the steps outlined in the “Your Rights” section above. Depending on your state of residence, you may make a request for a copy of the information up to twice per year per customer.

Responding to Requests

We will respond to requests within the time frame permitted by the applicable law. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

Identity Verification

We will take steps to verify your identity before processing your request. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have a LucyRX account, we may use our existing account authentication practices to verify your identity. If you do not have a LucyRX account, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

Authorized Agents

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provide written proof to us that he or she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please contact us at privacy@lucyrx.com.

Right to Non-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy law, such as denying you products and services, charging you different rates or prices including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you.

Right to Appeal

Under applicable law, if we decline to take the action requested pursuant to applicable law, we will notify you within 45 days from the receipt of your request and our justification for declining to take the requested action.  You may have the right to appeal our refusal to a requested action, and instructions on how to avail yourself of the right to appeal will be included in any communication related to your request.  We will reply to appeals informing you of any action taken or not taken in response to your appeal within 60 days of our receipt of your appeal.

Marketing

You may unsubscribe from our marketing communications at any time by following the “unsubscribe” link at the bottom of any such communication. Most promotional communications will also offer recipients choices about receiving additional messages.

California and Texas Residents

California and Texas law requires that we disclose the following additional information with respect to our privacy practices. If you are a California or Texas resident, this section applies to you in addition to the rest of this Privacy Policy.

California Shine the Light. California residents may request information concerning the categories of Personal Information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a request to us at privacy@lucyrx.com.

Categories of Personal Information We Collect and Our Purposes for Collection and Use. You can find a list of the categories of Personal Information that we collect in the “INFORMATION WE COLLECT” section above. For details regarding the sources from which we obtain Personal Information, please see the “INFORMATION WE COLLECT” section above. We collect and use Personal Information for the business or commercial purposes described in the “HOW WE USE YOUR INFORMATION” section above .

Categories of Personal Information Disclosed and Categories of Recipients. We disclose the following categories of Personal Information for business or commercial purposes to the categories of recipients listed below: