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FREIA PHARMA LLC – U.S. CONSUMER HEALTH DATA PRIVACY POLICY

 

Effective: March 31, 2024

Last Updated: July 1, 2025

 

Freia Pharma LLC (hereinafter referred to as “Freia Pharma LLC,” “we,” “our,” or “us”) is committed to safeguarding your privacy. We ask that you carefully review this Consumer Health Data Privacy Policy (this “Policy”). This Policy applies to the “consumer health data” (as that term is defined by applicable laws in Nevada and Washington) that Freia Pharma LLC collects, whether online or offline, wherever this Policy appears or is referenced.  By providing us with consumer health data or using or accessing our websites (“Sites”), mobile applications (“Apps”) (Sites and Apps, collectively, the “Platform”), our special offers (“Offers”) and our related services (collectively, the “Services”), you agree to the collection, use, and disclosure of your consumer health data, as described in this Policy.  If you do not agree, please do not provide us with consumer health data and do not access or use the Services.

This Policy supplements the Freia Pharma LLC U.S. Privacy Policy and applies solely to consumer health data, as described above.

 

CONSUMER HEALTH DATA WE MAY COLLECT

We (and the vendors and other parties we use to perform services on our behalf) may collect the following categories of consumer health data; the categories of consumer health data we collect from or about you specifically (if any) will depend on the context of your interactions with Freia Pharma LLC and the choices you make:

  • Information about a consumer’s health conditions, symptoms, status, diagnoses, testing, or treatments;
  • Measurements of bodily functions, vital signs, or characteristics;
  • Biometric information;
  • Genetic information;
  • Inferences about you;
  • Information that identifies a consumer seeking health care services; and
  • Other information that identifies your past or present health status

 

SOURCES OF CONSUMER HEALTH DATA

We may collect consumer health data directly from you. For example, we may collect consumer health data as part of information you submit, provide, or post (for example, feedback and other information you provide when you contact us or use our online chat features). Additionally, whenever you visit or interact with the Platform, Freia Pharma LLC or its vendors may use a variety of technologies such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies to passively collect information about your online and digital activity. For more information about how we use information that is collected passively, please see our U.S. Privacy Policy. Finally, we may acquire consumer health data about you from other sources, such as healthcare professionals, social networks, or select vendors (for example, business partners, service providers, analytics vendors, and advertising networks). We may also combine information about you that we receive from other parties with other information about you that we collect when you use the Platform or that you choose to share with us, and this combined information may in some instances be considered consumer health data.

 

PURPOSES FOR WHICH WE MAY COLLECT AND USE CONSUMER HEALTH DATA

We may collect and use consumer health data (a) to provide you with and administer the Services; (b) to fulfill and comply with our contractual and other obligations; (c) to provide support and respond to your inquiries, fulfill orders, contact and communicate with you when necessary; (d) to review the usage and operations of our Platform, develop new products or services, improve the Services, and conduct research and analyses to enhance or improve our content, products, and services; (e) for security, safety, compliance, and due diligence purposes; (f) to provide you with customized content or targeted offers; (g) to provide you with information, newsletters and promotional materials from Freia Pharma LLC and, or on behalf of, our marketing partners and affiliates; and (h) to create data in an aggregated format that may be used for analytical and demographic purposes.

Additionally, we may use consumer health data for other purposes for which we give you choices and/or obtain your consent or authorization as required by law. See the “Your Privacy Rights” and “Exercising Your Rights” sections below for more details on the controls and choices you may have.

 

HOW WE MAY SHARE CONSUMER HEALTH DATA

We may share your consumer health data for the purposes described above. Additionally, we may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any product or service you have requested or authorized, as described above. We may share your consumer health data with your health care professionals and our business partners.

We may also disclose your consumer health data (a) to vendors that provide business, professional, or technical support functions for us, help us operate our business and the Platform, or administer activities on our behalf; (b) to comply with law, or to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; (c) to protect the security of our Services, Platform, servers, network systems, databases, and business; (d) as necessary, if we believe that there has been a violation of our Terms of Use, any other legal document or contract related to our services, or the rights of any third party; and (e) to another entity that acquires or intends to acquire us or any of our assets in connection with a sale or bankruptcy or reorganization proceeding.

 

YOUR PRIVACY RIGHTS

Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

Confirmation and Access: You may request to confirm whether we collect, share, or sell consumer health data about you. You may also request to access such consumer health data, including a list of all third parties and affiliates with whom Freia Pharma LLC has shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties.

Deletion: You may request that we delete any of your consumer health data collected from you and retained by us.

Withdraw Consent: You may request to withdraw consent to Freia Pharma LLC’s collection and sharing of consumer health data concerning you.

We may deny your request to exercise any of the rights described above if doing so is reasonably necessary for us (or our affiliates or processors) to:

  • Prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable law;
  • Preserve the integrity or security of systems; or
  • Investigate, report, or prosecute those responsible for any such action that is illegal under applicable law.

EXERCISING YOUR RIGHTS

How to Submit a Request to Exercise Your Rights

To exercise your rights, please contact us using our webform, or contact us by email or mail at the addresses in the “Contact Information” section below. If you choose to email us, you must put the statement “Your Privacy Rights” in the subject field. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us.

Appealing Our Decision About Your Rights

We may deny certain requests and will explain why your request was denied and how to appeal our decision, as required by applicable law. After receiving our explanation, if you would like to appeal our decision, you may do so as further detailed in our communication back to you. For questions, you may also contact us by calling or emailing us at the contact information below.

 

CHANGES TO THE FREIA PHARMA LLC CONSUMER HEALTH DATA PRIVACY POLICY

We reserve the right, at our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Policy at any time. When we do, we will post the change(s) on the Platform.  Your continued use of the Services or Platform following the posting of changes to this Policy means you accept these changes.

 

CONTACT INFORMATION

If you have any questions or concerns about this Policy or the practices described herein, you may contact us at privacy@FreiaPharma.com, or by mail to:

Freia Pharma LLC

8 The Green, Ste A,

Dover, DE 1990

Attention: Chief Privacy Officer