Privacy Policy

EFFECTIVE: June 30, 2023

Shapiro MD™ Privacy Policy

Thank you for visiting the Shapiro MD™ website located at shapiromd.com (the “Site”). The Site is an Internet property of LifeMD, Inc. (collectively, “Shapiro MD™” “we,” “our” or “us”). This Shapiro MD™ Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when end-users (“user,” “you” or “your”): (a) access or use the Site; (b) access and/or download any of the: (i) blog posts, text, audio, video, photographs, graphics, artwork, testimonials and/or other content featured on the Site, including hair loss prevention-related content (collectively, “Informational Content”); and/or (ii) links to third party websites, products and/or services (“Third-Party Links,” and together with the Informational Content, the “Content”); (c) access links to Shapiro MD’s™ social media pages/accounts (collectively, “Social Media Pages”) on third-party social media websites, such as Facebook®, Instagram® and Twitter® (“Social Media Websites”); (d) access certain product review sections, message boards, comments sections, customer ratings and other interactive features of the Site (collectively, “Interactive Services”); (e) register to receive the Shapiro MD™ e-mail newsletter (“Newsletter”); (f) purchase any of the shampoos, scalp treatments, medications or other hair loss treatment-related items made available by and through the Site (collectively, the “Shapiro MD™ Nonprescription Products”) as provided by Shapiro MD™; (g) purchase prescription medications via the Site (“Prescription Medications,” and together with the Shapiro MD™ Nonprescription Products, the “Products”), as same are prescribed by certain third-party licensed medical doctors (“Healthcare Providers”) that provide telemedicine-related services in connection with the Site (“Telemedicine Services”); and/or (h) utilize the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Shapiro MD™ (collectively, the “Contact Services,” and together with the Site, Content, Social Media Pages, Shapiro MD™ Nonprescription Products, Newsletter, Prescription Medications and Telemedicine Services, the “Site Offerings”). Please note, if you are a resident of a European Union Member State, you are not permitted to use the Site and/or Site Offerings.

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by e-mailing us at: support@shapiromd.com; by calling us at: (877) 907-4047; or by sending us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

Capitalized terms not defined herein shall have the meanings set forth in the Shapiro MD™ Website Terms and Conditions (“Terms and Conditions”). IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

Instagram® and Facebook® are registered trademarks of Facebook, Inc. (“Facebook”). Twitter® is a registered trademark of Twitter, Inc. (“Twitter”). Please be advised that Shapiro MD™ is not in any way affiliated with Facebook or Twitter, nor are the Site Offerings endorsed, administered or sponsored by any of the aforementioned entities.

Your California Privacy Rights

Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: support@shapiromd.com; call us at: (877) 907-4047; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: support@shapiromd.com; call us at: (877) 907-4047; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for California Residents” below for a more complete description of your rights under the CCPA as a California State resident.

HIPAA/Protected Health Information

When you set up an account with Shapiro MD™, you are creating a direct customer relationship with Shapiro MD™ that enables you to access and/or utilize the various functions of the Site Offerings as a user. As part of that relationship, you may provide certain personal information to Shapiro MD™ that we do not consider to be “protected health information” or “medical information,” such as your name, email address, mailing/billing address and telephone number.

However, where you request Prescription Medications or otherwise request certain Shapiro MD™ Nonprescription Products, you may also provide certain health or medical information that may be protected under applicable laws, rules and regulations, such the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments (collectively, “HIPAA”). Shapiro MD™ is not considered a “covered entity” under HIPAA; provided, however, that our Healthcare Providers are “covered entities” under HIPAA and, in connection therewith, Shapiro MD™ may, in some cases, be a “business associate” of the Healthcare Providers. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to all of your transactions or communications with Shapiro MD™. To the extent Shapiro MD™ is deemed a “business associate” however, and solely in its role as a business associate, Shapiro MD™ may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to the Healthcare Providers (“PHI”). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.

The Healthcare Providers have adopted separate Notices of Privacy Practices that describe how they use and disclose Protected Information. By accessing or using any part of the Site Offerings, you acknowledge and agree that you have read all applicable Notices of Privacy Practices.

Your Nevada Privacy Rights

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third-party data broker, please e-mail us at: support@shapiromd.com; call us at: (877) 907-4047; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

Personal Information Collected

Use and Sharing of Personal Information

Non-Personal Information Collection and Use

Credit and/or Debit Card Transactions

Security of Your Personal Information

Children's Privacy

Opt-Out/Unsubscribe

Deleting, Modifying and Updating Your Information

Changes to this Privacy Policy

Contact Us

Personal Information Collected

Please see our Privacy Provisions for California Residents below for additional details regarding the categories of personal information collected.

For the purposes of this Privacy Policy, “personal information” shall mean individually identifiable information from or about an individual. We collect personal information when you access certain of the Site Offerings and complete the required information request Form(s) and/or otherwise provide such information to us. The information that you must supply on the Form(s) may include, without limitation: (a) your full name; (b) your mailing/billing address; (c) your e-mail address; (d) your telephone number; (e) your gender; (f) your credit card information (where purchasing Products); (g) answers to questions regarding your health and well-being, as asked via the medical intake form; and/or (h) any other information requested by us on the applicable registration Form.

For purposes of this Privacy Policy, items (f) and (g) in the preceding paragraph, as well as any Protected Information, will be considered “Sensitive Information.”

Use and Sharing of Personal Information

Please see our Privacy Provisions for California Residents below for details regarding our use and sharing of personal information.

Unless you affirmatively consent and/or affirmatively opt-in pursuant to an explicit request to do so, Shapiro MD™ will never share, sell, rent, exchange or barter your personal information to or with any third-party for financial gain or marketing purposes. Please be advised, however, that where you submit a request for Prescription Medication, we may share your personal information (including Sensitive Information and Protected Information) with our Healthcare Providers to enable them to evaluate your suitability for the applicable Prescription Medication.

By making your personal information available to Shapiro MD™, you grant Shapiro MD™ the right, subject to applicable law, to use that personal information to contact you by telephone and email regarding your use of the Site Offerings (including in connection with any purchase of Products). If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or see the “Opt-Out/Unsubscribe” section below.

Please be advised further that, by making your personal information available to Shapiro MD™, you also grant Shapiro MD™ the right to verify your identification via third party verification service providers (such as Woolly Labs, Inc. d/b/a Vouched). You acknowledge and agree that Shapiro MD™ may share your personal information with such third-party verification service providers for such purposes.

We may also use your personal information to send you promotional messages regarding various Shapiro MD™ Nonprescription products (as well as products and/or services offered by other LifeMD owned Internet properties such as Shapiro MD™, Rex MD™, Nava MD™, LifeMD™ and SoSRx™) and/or services, as well as third-party products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or use any of the other options available in the “Opt-Out/Unsubscribe” section below.

Where you submit personal information, we use the personal information that you make available to facilitate the delivery of the applicable Site Offerings to you, including the Products and to respond to any inquiries made by you. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include processing credit card and other payment transactions, sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ personal information (including Sensitive Information, where applicable) as needed to perform these functions for us, but we do not permit them to use user personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you for market research purposes. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive, from Shapiro MD™, telephone calls, including artificial voice calls, pre-recorded messages and/or calls (including text alerts via SMS text messages delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings, and your consent simply allows Shapiro MD™ to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Shapiro MD™ of the Phone Number Change via e-mail at: support@shapiromd.com, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information (including Sensitive Information): (i) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Shapiro MD™ is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third parties without permission.

Credit and/or Debit Card Transactions

Shapiro MD™ utilizes third-party service providers to provide credit and debit card payment processing services. If you choose to purchase Shapiro MD™ Nonprescription Products, the credit or debit card information provided will be shared with our contracted third-party payment processing service provider(s). Shapiro MD™ requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).

Non-Personal Information Collection and Use

Please see our Privacy Provisions for California Residents below for more details regarding the categories and types of non-personal information collected.

Computer IP Addresses/Browser Type

We may collect certain non-personally identifiable information about you and your desktop computer when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.

Cookies When a user visits the Site and/or interacts with one of our commercial e-mail messages, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable user’s computer and/or mobile device, as applicable. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience on the Site, as applicable. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing user preferences and tracking Site usage (such as pages opened and length of stay at the Site, as applicable).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking

Shapiro MD™ and its third-party partners, such as Google®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) to analyze trends, administer the Site, track users’ movements around the Site and to gather demographic information about our user base as a whole. In addition, we partner with third parties such as Google® to use Tracking Technology in connection with the display of advertising on our Site, and to manage the serving of our advertising to you on other websites when you exit the Site. Our third-party partners may use Tracking Technology to gather information about your activities on the Site and other websites in order to provide you with certain Shapiro MD™ advertising based upon your browsing activities and interests. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.

Users can opt-out of certain Google®-related tracking technology and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout.

In addition, users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. Further, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative, Facebook or Digital Advertising Alliance. Please note that opting out of this tracking activity does not opt you out of being served advertising. Even where you opt out of this tracking activity, you will continue to receive generic ads.

Cross Device Tracking

Shapiro MD™ tracks users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience. Shapiro MD™ may collect certain of your personal information across various devices. Please be advised that where you opt-out of having your use of the Site Offerings tracked across devices, you may need to upload certain information multiple times and/or input your log-in information multiple times.

Aggregate Data

Shapiro MD™ reserves the right to transfer and/or sell aggregate or group data about users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of users as a group, without disclosing personally identifiable information.

Interactive Services, Social Media Websites and Widgets

If you engage in any interaction with Shapiro MD™, other users or any third-party via the Interactive Services and/or by and through any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Interactive Services and/or Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Shapiro MD™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Shapiro MD’™ social media accounts. We are not responsible for the personal information that you choose to submit via Interactive Services and/or any Social Media Websites.

In addition, the Site contains Social Media Website widgets and buttons (“Widgets”), such as the Facebook® and Twitter® share buttons. These Widgets may collect your IP address, as well as which page you are visiting on our Site, and may set a Cookie on your browser to enable the Widget to function properly. The Widgets are owned and operated by the applicable Social Media Websites. The Social Media Websites operate independently from Shapiro MD™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices.

Your interactions with the Social Media Pages and Widgets are governed by the privacy policies of the applicable Social Media Websites. We encourage you to review the privacy policies and settings of the Social Media Pages with which you interact to help you understand those Social Media Websites’ respective privacy practices. If you have questions about the security and privacy settings of any Social Media Pages and/or Widgets that you use, please refer to the applicable Social Media Website’s privacy notices or policies.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, Social Media Websites, as well as the websites of third parties such as Healthcare Providers. Shapiro MD™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Shapiro MD™ has no responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts users to enter Sensitive Information (such as Protected Information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information), and when we store and transmit such Sensitive Information, that information is encrypted with industry standard encryption technology.

Access to your personal information is strictly limited, and we take reasonable security measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Children’s Privacy

Please see our Privacy Provisions for California Residents below for more details regarding the personal information of minors.

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Shapiro MD™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age.

Opt-Out/Unsubscribe

Please see our Privacy Provisions for California Residents below for instructions on how California Residents can opt-out of the sale of their personal information to third parties.

To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: support@shapiromd.com.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Shapiro MD™, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Shapiro MD™, as applicable.

Deleting, Modifying and Updating Your Information

Please see our Privacy Provisions for California Residents below for instructions on how California Residents can access and/or delete personal information that we have collected.

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have otherwise collected. You may do so by e-mailing us at: support@shapiromd.com. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Shapiro MD™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Shapiro MD™ will notify users by: (a) sending the modified policy to our users via e-mail; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, you may e-mail us as at: support@shapiromd.com; call us at: (877) 907-4047; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

Privacy Provisions for California Residents

These Privacy Provisions for California Residents (“Privacy Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Privacy Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in these Privacy Provisions. CA Users with disabilities who wish to access these Privacy Provisions in an alternative format can contact us by emailing us at: support@shapiromd.com; calling us at: (877) 907-4047; or sending us U.S. Mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated CA User information.
• Information excluded from the CCPA’s scope, such as:
  • health or medical information covered by HIPAA and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

• Directly from our CA Users. For example, from online registration forms that our CA Users submit to us in connection with the products and/or services that we offer by and through the Site. (Categories A, B, C, D and E)
• Indirectly from our CA Users. For example, through information we collect from our CA Users in the course of providing our products and/or services to them. (Categories A, B, C, D, E and F)
• Directly and indirectly from activity on the Site. This includes the type of browser that the CA User uses (e.g., Safari, Chrome, Internet Explorer), CA User IP address, the type of operating system used by the CA User (e.g., Windows or iOS) and the domain name of the CA User’s Internet Service Provider. In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third-party partners. (Category F)
• When our CA Users interact with us on our social media accounts, including commenting on and/or liking our posts. (Categories A, B, C, D, E and F)
• From third parties that interact with us in connection with the products and/or services that we offer to our CA Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from CA User lists, analyzing data and providing marketing analysis. (Categories A, B, C, D, E and F)

Use of Personal Information

Subject to your right to limit our ability to use the sensitive personal information that we collect from you, we may use or disclose the personal information that we collect (including: (a) name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card information (where purchasing Products); and (g) answers to health and well-being related questions, as asked via the medical intake form) for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for products and/or services, we will use that information to process your request. (Categories A, B, C, D, E and F)
• To provide you with information, products or services that you request from us. (Categories A, B, C, D, E and F)
• To create, maintain, customize and secure your account with us. (Categories A, B, C, D, E and F)
• To provide you with e-mail, direct mail and telemarketing messages concerning certain LifeMD, Inc. products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B, C, D, E and F)
• To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B, C, D, E and F)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Categories A, B, C, D, E and F)
• To improve the Site and better present its contents to you. (Categories A, B, C, D, E and F)
• For customer service purposes and to respond to inquiries from you. (Categories A, B, C, D, E and F)
• For testing, research, analysis and product development. (Categories A, B, C, D, E and F)
• As necessary or appropriate to protect our rights, property or safety, and that of our customers or others. (Categories A, B, C, D, E and F)
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, D, E and F)
• As described to you when collecting your personal information or as otherwise set forth in the CCPA. (Categories A, B, C, D, E and F)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A, B, C, D, E and F)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share your personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card information (where purchasing Products); and (g) answers to health and well-being related questions, as asked via the medical intake form) for the business purposes set forth above.

When we disclose personal information to a third-party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (e) telephone number; (f) your gender; (g) credit card information (where purchasing Products); and (h) answers to health and well-being related questions, as asked via the medical intake form) for a business purpose:

Category A Identifiers. Category B California Customer Records personal information categories. Category C Protected classification characteristics under California or federal law. Category D Commercial information. Category E Biometric information. Category F Internet or other similar network activity.

We disclose your personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card information (where purchasing Products); and (g) answers to health and well-being related questions, as asked via the medical intake form) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

• Our affiliates. (Categories A, B, C, D, E and F)
• Service providers. (Categories A, B, C, D, E and F)
• Third parties (including Healthcare Providers) to whom you authorize us to disclose your personal information in connection with the products and/or services that we provide to you. (Categories A, B, C, D, E and F)

In the preceding twelve (12) months, we have not sold personal information to third parties.

Retention of Personal Information

Shapiro MDTM may retain the categories of personal information set forth below for the period that is the greater of: (a) as long as Shapiro MDTM believes necessary; (b) as long as necessary to comply with Shapiro MD’sTM legal obligations, resolve disputes and/or enforce its agreements; and/or (c) as long as needed to provide CA Users with the products and/or services requested by such CA Users on the Site:

Category A Identifiers. Category B California Customer Records personal information categories. Category C Protected classification characteristics under California or federal law. Category D Commercial information. Category E Biometric information. Category F Internet or other similar network activity.

Shapiro MDTM may dispose of or delete any such information at any time, except as required by law, or as otherwise restricted by the terms and conditions set forth in any other agreement or document that is binding upon Shapiro MDTM.

Your Rights and Choices

The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:

• Clicking here
• Calling us at: (877) 907-4047;
• Emailing us at: privacy@shapiromd.com; or
• Sending us mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Sharing of Your Personal Information

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:

• Clicking here
• Calling us at: (877) 907-4047;
• Emailing us at: privacy@shapiromd.com; or
• Sending us mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information

You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category E (Biometric information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Shapiro MD™, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Shapiro MD™; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Shapiro MD™, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Shapiro MD™.

You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category E (Biometric information).

To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:

• Clicking here
• Calling us at: (877) 907-4047;
• Emailing us at: privacy@shapiromd.com; or
• Sending us mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract/relationship with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech rights, ensure the right of another CA User to exercise her/his free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, but only if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with CA User expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability and Deletion Rights

To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:

• Clicking here
• Calling us at: (877) 907-4047;
• Emailing us at: privacy@shapiromd.com; or
• Sending us mail to: LifeMD, Inc. (d/b/a Shapiro MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.

You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:

• Provide sufficient information that allows us to reasonably verify that you are: (1) the person about whom we collected personal information; or (2) an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; and/or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to these Privacy Provisions

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:

• Calling us at: (877) 907-4047;
• Emailing us at: privacy@shapiromd.com; or
• Sending us mail to: LifeMD, Inc. (d/b/a Shapiro MDTM), 800 Third Avenue, Suite 2800, New York, NY 10022.