1. Who We Are

Twinge Health LLC is a telehealth company incorporated in New York. We provide asynchronous telehealth services to adults ages 18 and older located in New York and Connecticut. Our affiliated physicians and pharmacists evaluate medical intake forms and, if medically appropriate, issue prescriptions for compounded pain creams through Friendly Pharmacy or another pharmacy selected by the user.

2. Information We Collect

We collect both Personal Information and Protected Health Information (PHI), as defined under applicable law.

A. Personal Information
May include:

  • Full name
  • Date of birth
  • Mailing address
  • Phone number
  • Email address
  • Gender
  • IP address
  • Browser/device type
  • Marketing preferences

B. Protected Health Information (PHI)
May include:

  • Medical history and conditions
  • Symptoms, medications, allergies
  • Photographs or uploaded files
  • Physician-patient communications
  • Pharmacy preferences
  • Treatment notes or recommendations
  • Prescriptions and prescription status

C. Technical and Usage Data
We automatically collect:

  • IP address and device identifiers
  • Browser type and language
  • Pages visited and session duration
  • Referring pages or search terms
  • Cookie and tracking technology data

We collect this information:

  • Directly from you (via forms, chats, uploads)
  • Automatically through cookies and analytics tools
  • From our providers or pharmacy partners when required for care or delivery

3. How We Use Your Information

We use the information collected for the following purposes:

A. Medical and Operational Use

  • Evaluate your intake form and determine if a prescription is medically necessary
  • Facilitate communication with licensed physicians and pharmacists
  • Prescribe and deliver medications via a licensed compounding pharmacy
  • Contact you about your care, prescription, or refund status

B. Platform Management and Improvement

  • Improve user experience, performance, and content
  • Analyze usage patterns to improve platform functionality
  • Debug, troubleshoot, and administer the platform

C. Legal and Regulatory Compliance

  • Maintain HIPAA-compliant records
  • Satisfy legal obligations (e.g., fraud prevention, government inquiries)
  • Respond to lawful requests by public authorities

D. Marketing and Retargeting (With Consent)

  • Display personalized ads using Facebook Pixel
  • Analyze engagement through Google Analytics
  • Send newsletters or product updates if you opt in

We do not use your PHI for marketing purposes without explicit, written authorization as required by HIPAA.

4. How We Share Your Information

We do not sell your personal or health information. We may share it under the following limited circumstances:

A. With Licensed Healthcare Providers
Your information is shared with physicians and pharmacists affiliated with Twinge Health for the purpose of evaluating and treating your condition.

B. With Pharmacy Fulfillment Partners
If a prescription is issued, your information is securely transmitted to Friendly Pharmacy or another pharmacy you choose for dispensing.

C. With Third-Party Service Providers
We may share your information with:

  • Cloud hosting and data storage providers (e.g., MongoDB Atlas)
  • Communication platforms (e.g., email/SMS services)
  • Marketing platforms (e.g., Facebook Ads, Google Analytics)

All third-party providers are bound by confidentiality agreements and required to implement safeguards consistent with HIPAA and industry standards.

D. As Required by Law
We may disclose your information if:

  • Required to comply with a court order, subpoena, or legal process
  • Necessary to prevent, investigate, or take action regarding suspected fraud or safety threats
  • Needed to protect our legal rights, property, or the rights of others

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience and understand user behavior. These technologies help us:

  • Remember your preferences
  • Measure website traffic
  • Track advertising effectiveness
  • Show you personalized ads on platforms like Facebook

You may adjust your cookie preferences through the cookie consent banner or your browser settings. Essential cookies are required for core functionality.

We use:

  • Google Analytics
  • Meta (Facebook) Pixel

You can opt out of tracking via:

6. Email and Communication Preferences

If you opt in, we may send:

  • Appointment reminders
  • Order confirmations
  • Newsletters
  • Special offers and health content

You may opt out at any time by clicking the unsubscribe link in our emails or contacting care@twingehealth.com.

We may still send essential communications regarding your order or care, even if you opt out of marketing.

7. Data Retention and Storage

We retain personal and health information for as long as necessary to:

  • Fulfill the purpose for which it was collected
  • Comply with legal obligations
  • Resolve disputes and enforce agreements

Data is stored securely in cloud databases using encrypted storage and transmission protocols. We use industry-standard safeguards to protect your information.

8. Your Rights and Choices

You may have the right to:

  • Access your data and request a copy
  • Correct inaccurate or incomplete data
  • Request deletion of your data (where legally permissible)
  • Withdraw consent for marketing communications
  • File a complaint if you believe your rights were violated

To exercise these rights, email care@twingehealth.com. We may verify your identity before responding.

9. California and State Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

  • Right to know what personal data we collect
  • Right to delete personal data (with exceptions)
  • Right to opt out of sale (we do not sell your data)
  • Right to non-discrimination for exercising your rights

We extend similar rights to all users, where applicable by law.

10. Security Practices

We implement technical, physical, and administrative safeguards to protect your data, including:

  • End-to-end encryption of sensitive data
  • Role-based access controls
  • Audit logs and monitoring
  • Secure authentication

Despite our efforts, no system can be 100% secure. You use the service at your own risk and should protect your login credentials.

11. Children's Privacy

Twinge Health is not intended for children under 18. We do not knowingly collect or process information from minors. If we discover a user is underage, their information will be deleted.

12. External Websites

This Policy does not apply to third-party websites that may be linked from our site. We are not responsible for their privacy practices.

13. Changes to This Policy

We may update this Privacy Policy periodically. The latest version will always be posted on our website with the "Effective Date" noted at the top. Significant updates will be communicated to you by email or through an in-app notice.

14. Contact Information

If you have questions or wish to exercise your privacy rights, please contact:

Twinge Health LLC
1 New York Lane
New York, NY 10040
Email: care@twingehealth.com