DrBrainRX Privacy Policy

Last Updated: December 2nd, 2025

Siavoshi, Inc. d/b/a DrBrainRX (“DrBrainRX,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you access or use our website (www.drbrainrx.com), patient portal, communication tools, online forms, scheduling systems, and any related services (collectively, the “Services”).

By using the Services, you agree to the data practices described in this Privacy Policy.

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1. Scope: When This Policy Applies vs. When HIPAA Applies

Some of the information we collect may be “Protected Health Information” (“PHI”) governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

1.1 Information governed by HIPAA

If you create a patient account, seek medical evaluation, communicate with a clinician, or otherwise engage in activities related to medical treatment or care, the information you provide becomes PHI. PHI is governed by our Notice of Privacy Practices (“NPP”), not this Privacy Policy.

Our NPP explains how we use and disclose PHI for:

• treatment

• payment

• healthcare operations

You can view our Notice of Privacy Practices here:
[INSERT LINK TO NPP]

1.2 Information governed by this Privacy Policy

Information collected through:

• website browsing

• forms before establishing a clinician-patient relationship

• marketing and retargeting activities

• general customer service communications

…is not PHI and is governed by this Privacy Policy.

Participation in introductory calls or submission of information through the Services does not establish a clinician–patient relationship.

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2. Information We Collect

We collect the following categories of personal information:

2.1 Information you provide

• Name

• Email address

• Mailing/billing address

• Phone number

• Demographic information

• Information submitted through forms or inquiries

• Account credentials

• Health-related information prior to becoming a patient

2.2 Information automatically collected

We and third-party partners collect:

• IP address

• Browser type and device type

• Pages visited and time spent

• Referral URLs

• Advertising identifiers

• Cookies, pixels, beacons, and similar technologies

2.3 Information from third parties

We may receive information from:

• payment processors

• advertising partners

• analytics platforms

• pharmacies and healthcare partners (if applicable)

2.4 De-identified data

We may de-identify personal information in accordance with applicable law and may use or disclose de-identified data for any lawful purpose.

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3. How We Use Personal Information

We use your information to:

3.1 Deliver and improve the Services

• Provide access to the website and portal

• Process your submissions

• Communicate with you

• Personalize your experience

3.2 Healthcare-related functions (when applicable)

For PHI specifically, see our NPP.

3.3 Marketing and communications

• Send updates and promotions

• Deliver targeted advertising

• Analyze campaign performance

3.4 Security and compliance

• Detect and prevent fraud

• Enforce our Terms of Service

• Comply with legal obligations

3.5 Corporate transactions

We may use or disclose information in connection with a merger, acquisition, financing, or sale of assets.

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4. Cookies and Tracking Technologies

We use cookies, pixels, and other tracking tools to:

• understand site behavior

• personalize content

• analyze marketing performance

• deliver retargeted advertising

4.1 Advertising platforms we use

You may encounter tracking from:

• Meta (Facebook, Instagram)

• Google Ads and Analytics

• TikTok

• Third-party ad networks

4.2 Your choices

You may:

• adjust your browser settings

• use the Network Advertising Initiative opt-out tool (www.networkadvertising.org/choices)

• use Google’s Ad Settings (www.google.com/settings/ads)

• opt out of Meta ads (www.facebook.com/ads/preferences)

Please note disabling cookies may affect the functionality of the Site.

Our Services currently do not respond to “Do Not Track” signals.

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5. How We Share Personal Information

We do not sell personal information.

We may share information with:

• service providers (hosting, email, analytics, scheduling, SMS platforms)

• pharmacies or healthcare partners when necessary for care

• advertising and analytics partners

• legal authorities when required

• buyers or successors in a corporate transaction

All service providers are required to maintain confidentiality.

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6. Data Retention

We retain personal information for as long as necessary to:

• provide the Services

• satisfy legal, accounting, or reporting requirements

• maintain business records

PHI retention is governed by HIPAA and state medical record laws.

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7. Security

We implement reasonable technical, administrative, and physical safeguards to protect information.
However, no system is perfectly secure.

If you access the Services on a mobile device, some information may be stored on the device temporarily. We cannot guarantee that mobile device safeguards will prevent all unauthorized access.

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8. Minors

Our Services are not intended for individuals under age 18 without parental involvement.

We do not knowingly collect information from children under 13.
If you believe a child under 13 has provided information, contact us and we will delete it.

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9. Your Privacy Rights

Depending on your location, you may have certain rights.

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10. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• know what categories of personal information we collect

• request deletion

• request correction

• opt out of sharing for cross-context behavioral advertising

• limit use of sensitive data (if applicable)

We do not sell personal information.

10.1 Categories of Information Collected

California residents may submit requests to: INFO@drbrainrx.com

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11. Nevada Residents

We do not sell covered information as defined under Nevada law.
Requests may be sent to privacy@drbrainrx.com.

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12. EU/UK Visitors (GDPR-style disclosures)

If you are located in the European Economic Area or UK, you may have rights to:

• access

• correct

• delete

• restrict processing

• object to processing

• data portability

We process data based on:

• your consent

• our legitimate interests

• performance of a contract

• legal obligations

Requests may be sent to privacy@drbrainrx.com.

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13. Changes to This Policy

We may update this Privacy Policy periodically.
Revisions will be posted with an updated “Last Updated” date.

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14. Contact Us

For questions or to exercise rights:

Email: info@drbrainrx.com
Website: www.drbrainrx.com