Privacy Policy

    Privacy Policy

    This Privacy Policy describes the data protection practices of Vivo Health LLC. Your health information is handled under a different framework than your website information.

    Effective July 15, 2026 · Last updated July 15, 2026

    Introduction

    This Privacy Policy (“Privacy Policy”) describes the data protection practices of Vivo Health LLC (“Vivo,” “we,” “our,” or “us”), including when you visit our website at https://www.vivoclinic.org/ or any Vivo subdomain (collectively, our “Websites”), or otherwise provide data to Vivo. We refer to the Websites and the other services provided by Vivo together in this Privacy Policy as the “Services.” This Privacy Policy is incorporated into our Terms of Service. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Service.

    PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

    Vivo is a technology and administrative services company. Vivo does not practice medicine and does not dispense medication. Clinical services are provided by Arora Health & Aesthetics, LLC (the “Medical Group”), an independent professional entity. Medication, where prescribed, is compounded and dispensed by VialsRX (the “Pharmacy”), an independent state-licensed 503A compounding pharmacy.

    This distinction determines how your information is handled, so we state it plainly:

    What it covers

    Who governs it

    Protected Health Information (PHI). Your intake responses, medical history, prescription records, and clinical communications.

    Held by the Medical Group and the Pharmacy, which are HIPAA covered entities. Their use and disclosure of PHI is governed by the Notice of Privacy Practices, not by this Privacy Policy. Vivo accesses PHI only as a Business Associate, under a written Business Associate Agreement, and only to perform administrative services on their behalf.

    Consumer data. Your name, email, shipping address, device and browsing data, marketing preferences, and payment metadata, collected before or outside a clinical encounter.

    Governed by this Privacy Policy, and by California and other state consumer privacy laws.

    Where these overlap, the stricter rule applies. If information in our possession is PHI, we treat it as PHI regardless of how it reached us. Where anything in this Privacy Policy conflicts with the Notice of Privacy Practices as to PHI, the Notice of Privacy Practices governs.

    This Privacy Policy contains the following sections:

    Protected Health Information and HIPAA

    When you create an account with Vivo, you establish a direct customer relationship with Vivo. The information you provide for that purpose — your name, email address, shipping address, phone number, and transactional information — is not protected health information, and is handled under this Privacy Policy.

    The clinical information you submit through an intake is different. Vivo is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). The Medical Group and the Pharmacy are covered entities. Vivo accesses your protected health information solely as a Business Associate of those entities, under a written Business Associate Agreement, and only to perform administrative services on their behalf.

    The Medical Group has adopted a Notice of Privacy Practices describing how it uses and discloses protected health information and the rights you have with respect to it. By using the Services, you acknowledge receipt of the Notice of Privacy Practices. Requests concerning your medical record — including access, amendment, an accounting of disclosures, or restrictions — must be directed to the Medical Group’s Privacy Officer as described in that Notice. Vivo cannot fulfill a request for your medical record.

    Vivo is not a HIPAA covered entity, but other laws apply to Vivo directly. These include California’s Confidentiality of Medical Information Act and the consumer health data laws of several states. See “Privacy Information for California Residents” and “Privacy Information for Residents of Other States” below.

    The Information We Collect and the Sources of Such Information

    We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

    1. Information You Provide to Us

    We collect information that you provide directly to us, for example through:

    The specific types of information we collect depend on the Services you use and the information you choose to provide. The types of data we collect directly from you include:

    We do not collect Social Security numbers, driver’s license or passport numbers, other government-issued identifiers, biometric identifiers, or information about your sex life or sexual orientation.

    2. Information We Collect Through Automated Means

    We collect certain information about your use of the Services and the device you use to access them.

    Our Websites. When you use our Websites, we collect and analyze information such as your IP address, browser type and language, operating system, referring and exit pages and URLs, pages viewed and the order in which you viewed them, the amount of time spent on particular pages, interaction events, the date and time of your visit, and error logs.

    Location information. We infer general location only — such as state, city, or postal code associated with your IP address. We use this because eligibility for the Services depends on the state in which you are physically located, and because sales tax depends on your address. We do not collect precise GPS location information, and we do not ask for it.

    Cookies and similar tools. We use cookies and similar technologies to operate the Websites and collect the information described in this section. A cookie is a small text file placed on your device when you visit a site, which allows a web server to recognize your browser over time.

    We do not use advertising or social-media pixels on the Websites, and we do not use software development kits (SDKs) or mobile advertising identifiers. We do not operate a mobile application.

    You can change your browser settings to notify you when a cookie is being set, or to block cookies altogether. Please consult the “Help” section of your browser for more information. Blocking strictly necessary cookies may prevent you from logging in to your account.

    Email. Our email messages contain a small embedded image that tells us whether a message was opened and whether links in it were clicked. We use this to understand whether our communications are being received and are useful. You can prevent this by configuring your email client to block automatic image loading, which most email clients allow.

    3. Information We Collect From Social Media and Other Content Platforms

    If you “like,” follow, tag, or message us on a social media platform, we may receive your handle, your name, and any content you post that relates to us. We may also collect information you submit to us through a social media platform in connection with a promotion. We do not receive health information through social media, and we ask that you not send any.

    4. Information We Receive From Other Sources

    The Medical Group, the Pharmacy, our platform vendor, our payment processor, and shipping carriers may provide us with fulfillment status, order events, and administrative data in connection with the Services you have requested.

    We do not purchase personal information from data brokers, and we do not receive information about you from advertising networks.

    Purposes for How We Use Your Information

    In connection with providing you with the Services, we use your information to:

    We do not use protected health information for marketing. Marketing communications are sent based on your consumer relationship with Vivo and the preferences you have stated — not on your diagnosis, your intake answers, or your prescription record.

    Aggregate/De-Identified Information. We may aggregate or de-identify information so that it can no longer reasonably be linked to you or your device, and use it to measure and improve the Services. We maintain de-identified information in de-identified form and do not attempt to re-identify it. We do not sell, license, or disclose de-identified information derived from health information to advertisers, data brokers, or advertising intermediaries. De-identification of protected health information is performed only in accordance with HIPAA and only as permitted by the applicable Business Associate Agreement.

    Online Analytics and Advertising

    1. Online Analytics

    We use Google Analytics and Google Tag Manager to collect and analyze usage information through cookies and similar tools, in order to understand how the Websites perform and to improve them. These services may assign your browser or device a pseudonymous identifier. Google processes this information as described in Google’s own privacy policy and terms; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

    We do not use Google Signals, Google User-ID, cross-device identity resolution, or any other feature designed to link your activity across browsers or devices.

    To prevent Google Analytics from using your information, you may:

    2. Online Advertising

    We do not currently engage in online behavioral or interest-based advertising. Specifically:

    If these practices change, we will update this Privacy Policy with a revised “Last Updated” date before the change takes effect, and will obtain your consent where the law requires it. We will not begin a new practice and describe it afterward.

    3. Notice Concerning Global Privacy Control and Do Not Track

    Global Privacy Control (“GPC”). Some browsers and browser extensions support GPC, which sends a signal indicating your choice to opt out of certain data processing, including sale and sharing. We honor GPC and other recognized opt-out preference signals as valid opt-out requests. Because we do not sell or share personal information, GPC does not change our practices — we honor it regardless.

    Do Not Track (“DNT”). DNT is a privacy preference available in certain browsers. Unlike GPC, there is no common understanding of how a DNT signal should be interpreted and no legal standard defining a response to it. We therefore do not respond to browser-initiated DNT signals. We instead provide the controls described above — our consent banner, GPC, browser cookie controls, and the Google Analytics Opt-out Browser Add-on — each of which we do honor.

    How We Share and Disclose Your Information

    We share your information in the following ways:

    Arora Health & Aesthetics, LLC (the Medical Group). To route your intake for clinical review and to support the clinical services you request.

    VialsRX (the Pharmacy). To fulfill a prescription issued by a clinician.

    Bask Health (platform vendor). Telehealth and pharmacy infrastructure. Bound by a Business Associate Agreement.

    Stripe (payment processor). To process transactions. Stripe’s handling of your information is governed by its own privacy policy, available at stripe.com/privacy.

    Google (analytics). Usage and device data collected through Google Analytics and Google Tag Manager, to measure and improve the Websites. Google does not receive your intake responses, prescription record, purchases, or the content of any clinical communication.

    Shipping carriers. To deliver your order.

    Email and customer relationship platform. To send transactional and opted-in marketing messages. Bound by a Business Associate Agreement where applicable, and configured to exclude protected health information.

    Professional advisors. Counsel, accountants, and auditors, under confidentiality obligations.

    Protection of Vivo and Others. We may access, retain, and disclose information about you where we believe it is reasonably necessary to: (a) comply with legal process such as a subpoena or court order; (b) enforce our Terms of Service, this Privacy Policy, or another contract with you, including investigating potential violations; (c) respond to your requests for customer service; or (d) protect the rights, property, or personal safety of Vivo, its users, or the public, including preventing fraud or serious harm.

    Business Transfers. In connection with a merger, acquisition, financing, or sale of assets, your information may be among the transferred assets, subject to this Privacy Policy or a successor policy with equivalent protections. Where applicable law imposes additional restrictions on the transfer of health data, we will comply with those restrictions.

    Reviews and Content Submitted for Publication. If you submit a review or testimonial for publication, it is not confidential, and we may display it publicly along with any name you provide. Please do not include health information you do not want made public.

    At Your Direction. We may disclose your information in other ways you direct us to, or where you have consented.

    Any service provider that receives protected health information on our behalf does so under a Business Associate Agreement, as HIPAA requires. Advertising and analytics providers never receive protected health information.

    We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

    Your Marketing Choices

    You may instruct us not to contact you by email, text message, or phone regarding products, services, promotions, and events by emailing us at care@vivoclinic.org, by using the unsubscribe link at the bottom of any marketing email, or by replying STOP to any marketing text message.

    Please note that, regardless of your request, you may not opt out of transactional communications — such as order confirmations, shipping notifications, prescription and reassessment notices, and account status messages — while you have an active subscription. These are part of the Services. To stop them, cancel your subscription.

    Third Party Services and Notice About Health Information

    This Privacy Policy does not address, and we are not responsible for, the privacy, information, or security practices of any third party — including the Medical Group, its clinicians, the Pharmacy, the manufacturer of your device, or any third-party website or service to which the Services may link. These third parties may gather information from or about you. We have no control over their privacy practices, and their collection, use, and disclosure of your information is subject to their own privacy policies and not this one. We urge you to read them.

    For protected health information held by the Medical Group or the Pharmacy, see the Notice of Privacy Practices.

    How We Protect Your Information

    Vivo maintains administrative, technical, and physical safeguards designed to protect your information against accidental or unlawful destruction, accidental loss, alteration, and unauthorized disclosure or access. These include encryption of information in transit and at rest, role-based access controls, multi-factor authentication on administrative accounts, credential management through a password manager, vendor due diligence, and logging.

    However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. You acknowledge and accept that we cannot guarantee the security of information transmitted to, through, or on the Services, and that any such transmission is at your own risk.

    Email and text messages are not encrypted. If you choose to send or receive health information by email or text message, you do so at your own risk. For anything sensitive, use the secure messaging function inside your account.

    You are responsible for keeping your password confidential and for all activity under your account. Please do not share your password with anyone. Anyone with access to your device may be able to access your account. Notify us immediately at care@vivoclinic.org if you believe your account has been compromised.

    We maintain an incident response process and will notify affected individuals and regulators as required by law.

    Retention of Your Information

    We keep your information for no longer than necessary for the purposes for which it is processed, and thereafter as required by law. The period depends on the category of information:

    Category

    Retention period

    Account and contact information

    For the life of your account, plus 3 years after closure

    Order and transaction records

    7 years, to meet tax, accounting, and audit obligations

    Payment metadata (token, last four digits, brand, expiration)

    For the life of your account, plus 3 years

    Customer service correspondence

    3 years from the date of the last message

    Analytics and device data

    Up to 14 months

    Marketing preferences and opt-out records

    Indefinitely, so that we can continue to honor your opt-out

    Reviews and testimonials submitted for publication

    Until you ask us to remove them, or we remove them

    Employment applications

    3 years

    Medical records and prescription records are retained by the Medical Group and the Pharmacy under their own state-law retention schedules — typically a minimum of seven to ten years — and are not deleted at Vivo’s discretion. Deletion of your Vivo account does not delete your medical record.

    Privacy Information for California Residents

    If you are a California resident, California law requires us to provide you with additional information about how we collect, use, and share your “personal information” as defined in the California Consumer Privacy Act (“CCPA”). This section also serves as our notice at collection.

    Categories of personal information we collect and disclose

    Please note that some of the information collected through the Services — including protected health information — is subject to HIPAA and other health data privacy laws, and is therefore not subject to the CCPA. The chart below covers only CCPA-governed personal information.

    Category of Personal Information

    Categories of Third Parties to Which We Disclose

    Identifiers and contact information (name, address, email address, phone number, account name, date of birth)

    The Medical Group; the Pharmacy; platform vendor; payment processor; shipping carriers; email/CRM platform; professional advisors; entities for legal and fraud prevention

    Commercial and transactional information (orders, subscription status, purchase history)

    The Medical Group; the Pharmacy; platform vendor; payment processor; shipping carriers; professional advisors; entities for legal and fraud prevention

    Financial information (payment token, card brand, last four digits, expiration date)

    Payment processor; professional advisors; entities for legal and fraud prevention

    Internet or other network or device activity (IP address, browser and device data, pages viewed, interaction events)

    Analytics provider; platform vendor; entities for legal and fraud prevention

    Geolocation information (general location inferred from IP address — we do not collect precise location)

    Analytics provider; platform vendor; entities for legal and fraud prevention

    Customer service data (information you provide through support requests or correspondence with our Care Team)

    Platform vendor; email/CRM platform; entities for legal and fraud prevention

    User-generated content (reviews and testimonials you submit for publication)

    Platform vendor; the public, where you submit content for publication

    Sensitive personal information (account log-in credentials)

    Platform vendor only, to authenticate you

    The business purposes for which we use this information are described in “Purposes for How We Use Your Information” above. Retention periods are described in “Retention of Your Information” above.

    We do not sell any category of personal information listed above, and we do not share any category for cross-context behavioral advertising.

    Your California privacy rights

    The CCPA allows you to request that we:

    The CCPA further provides you with the right not to be discriminated against for exercising your rights.

    Confidentiality of Medical Information Act (CMIA)

    California law may treat Vivo as a provider of health care with respect to medical information, independently of HIPAA, because we offer software designed to maintain medical information for consumers. Where CMIA applies:

    These protections are in addition to — not instead of — the HIPAA protections described in the Notice of Privacy Practices.

    Exercising your rights

    If you are a California resident and would like to exercise any of your rights, email us at care@vivoclinic.org. Please include your full name and the email address associated with your use of the Services, along with the rights you would like to exercise.

    We will verify your identity to the degree of certainty required by law before responding — typically by confirming that the request comes from the email address on your account. We will respond within 45 days, extendable by an additional 45 days with notice to you.

    Authorized agents. You may designate an authorized agent, in writing or through a power of attorney, to make a request on your behalf. We will require the agent to provide proof of authorization, and we may need to verify your identity directly with you.

    When we may decline. To the extent permitted by law, we may decline a request where granting it would be prohibited by law, would adversely affect the privacy or other rights of another person, would reveal a trade secret or confidential information, or would interfere with a legal obligation requiring retention; where we cannot authenticate you as the person to whom the information relates; or where the request is unreasonable or excessive. If we decline, we will tell you why.

    Important limit — medical records. Protected health information held by the Medical Group or the Pharmacy, and information Vivo holds as their Business Associate, is exempt from the CCPA and governed instead by HIPAA. Direct those requests to the Medical Group’s Privacy Officer as described in the Notice of Privacy Practices. Vivo cannot fulfill a request for your medical record, and will not transmit medical records by unencrypted email.

    Shine the Light Disclosure

    The California “Shine the Light” law (Cal. Civ. Code § 1798.83) gives California residents the right, under certain circumstances, to request information from us regarding the manner in which we share certain categories of personal information with third parties for those third parties’ own direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

    Privacy Information for Nevada Residents

    Under Nevada law (NRS 603A), certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. We do not engage in such activity. However, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sale by emailing care@vivoclinic.org. We will take reasonable steps to verify your identity and the authenticity of the request, and once verified, we will maintain your request in the event our practices change.

    Nevada’s SB 370 imposes additional consent and disclosure requirements on consumer health data. We honor those requirements through the same channel.

    Privacy Information for Residents of Other States

    Residents of other states with comprehensive consumer privacy laws — including Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, and Washington — have comparable rights of access, correction, deletion, portability, and opt-out.

    Washington’s My Health My Data Act imposes additional consent, disclosure, and authorization requirements on consumer health data, and provides a private right of action. Several states — including New York, Texas, Florida, Illinois, and Massachusetts — provide heightened protection for specific categories of health information, such as mental health records, HIV-related information, genetic testing results, and substance use treatment records. Where those protections apply to information held by the Medical Group or the Pharmacy, they are addressed in the Notice of Privacy Practices.

    If you are a resident of any state with a comprehensive consumer privacy or consumer health data law, you may exercise the rights that law provides by emailing care@vivoclinic.org, whether or not your state is named above. We will honor those rights through the same process described in the California section.

    Children

    The Services are intended only for individuals 18 years of age or older. The Services are not directed to, and are not designed to attract, anyone under 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we will stop using it and delete it, except where the law requires retention or where it is maintained as part of a medical record by the Medical Group or the Pharmacy. If you believe someone under 18 has provided us with information, contact us at care@vivoclinic.org.

    Revisions to Our Privacy Policy

    We reserve the right to change this Privacy Policy to reflect changes in the law, in our data collection and use practices, in the features of our Services, or in technology. We will make the revised Privacy Policy accessible through the Services, and the date it was last revised is identified at the top of this document.

    If we make a material change, we will provide you with appropriate notice in accordance with legal requirements. Where a change would materially expand how we use information we have already collected, we will obtain your consent where the law requires it. We will not apply a new practice retroactively to information you provided under a different commitment, and we will not begin a new practice and describe it afterward.

    Your continued use of the Services after such amendments and notice will be deemed your acknowledgment of the changes to this Privacy Policy.

    Contacting Us

    If you have any questions about this Privacy Policy or Vivo’s privacy practices, please contact us at:

    Vivo Health LLC
    721 East Broadway, Suite A
    Glendale, CA 91205
    United States

    care@vivoclinic.org
    +1 (762) 327-2774

    For questions about protected health information, contact the Medical Group’s Privacy Officer as described in the Notice of Privacy Practices.