Privacy Policy

This Privacy Policy is issued by Redox Medical Group, 9100 Wilshire Blvd. Ste. 700W, Beverly Hills, California 90212 ("Redox", "we", "us" or "our"). It applies to the website located at redoxpen.com (the "Site"), to the prescriber access request and waitlist form on the Site, and to any email or other correspondence that results from a submission you make through the Site. It does not apply to the practices of any pharmacy, clinic or other organisation that you deal with separately, even where we refer you to them, and it does not apply to products or websites operated by other companies.

The Site is intended for licensed healthcare practitioners in the United States. By using the Site or submitting the access request form you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please do not use the Site or submit the form.

When you complete the access request or waitlist form we collect the information you enter: your first and last name, your email address, your telephone number, and whether the submission is an access request or a waitlist registration. If you contact us by email in response to that submission, we also receive the contents of your message and any information you choose to include, such as your professional credentials, practice name or licensing details.

The Site does not ask for, and you should not submit through it, any information about an identified patient. Patient health information should only ever be exchanged through the secure channels that are established after a practitioner has been enrolled.

Like most websites, our web server records standard technical information when you visit: the IP address of your device, the type and version of your browser and operating system, the pages you request, the date and time of the request, and the page that referred you to the Site. This information is held in server logs, is used for security, capacity planning and troubleshooting, and is not combined with the details you give us in the form except where necessary to investigate abuse or a security incident.

The Site sets only the cookies that are strictly necessary for it to work. Our form provider uses a session token to protect the form against automated submissions, and WordPress may set a short-lived cookie to remember your preferences within a single visit. We do not currently use advertising cookies, cross-site tracking pixels or third-party analytics on the Site. If we introduce analytics or other non-essential cookies in future, we will update this policy and, where the law requires it, ask for your consent before they are set.

You can control cookies through your browser settings, including blocking or deleting them. Blocking strictly necessary cookies may prevent the form from being submitted.

We use the information described above for the following purposes:

• To respond to your access request or waitlist registration. We use your name, email address and telephone number to contact you about the availability of the Redox Smart Pen, to verify that you are a licensed practitioner, and to explain the enrolment process.
• To manage limited access. The number of access requests we have received determines whether the Site offers immediate access requests or waitlist registrations, so each submission is counted for that purpose.
• To operate, secure and improve the Site. Server logs help us detect misuse, keep the Site available and understand how it is performing.
• To comply with law. We may use information where necessary to meet legal, regulatory or professional obligations, to respond to lawful requests from public authorities, or to establish, exercise or defend legal claims.

We do not sell personal information and we do not use it for automated decision-making that produces legal or similarly significant effects.

Where data protection law requires a legal basis for processing, we rely on: your consent, given when you submit the form, for contacting you about the Redox Smart Pen; the steps necessary to enter into a relationship with you at your request, for verifying credentials and managing enrolment; our legitimate interests in operating a secure and reliable website, provided those interests are not overridden by your rights; and compliance with legal obligations that apply to us. You may withdraw consent at any time by contacting us, without affecting processing that took place before withdrawal.

We share personal information only in the following circumstances:

• Service providers. Companies that host the Site, deliver our email, and process form submissions on our behalf. They may access information only to perform those services for us and are bound by obligations of confidentiality.
• Pharmacy and fulfilment partners. If you enrol as a prescriber, we share the information needed to set up your account with the 503A compounding pharmacy that dispenses the Redox Smart Pen and with the partners that fulfil and ship orders. We will tell you who these partners are before that sharing takes place.
• Professional advisers. Lawyers, accountants, auditors and insurers, where necessary for the operation of our business.
• Legal and safety. Where disclosure is required by law, subpoena or court order; to protect the rights, property or safety of Redox, our practitioners, their patients or the public; or in connection with the investigation of suspected fraud, security incidents or violations of our Terms of Use.
• Business transfers. If Redox is involved in a merger, acquisition, financing or sale of assets, personal information may be transferred as part of that transaction, subject to the commitments made in this policy.

We do not share, sell or rent your information to third parties for their own marketing purposes.

We keep access request and waitlist submissions for as long as we are evaluating or maintaining a prescriber relationship with you, and for up to three years after our last contact with you so that we can respond to follow-up questions and meet record-keeping obligations. Server logs are retained for up to twelve months. We keep information for longer where a law, regulation, legal hold or dispute requires it. When information is no longer needed we delete it or make it anonymous.

We protect personal information with technical and organisational measures appropriate to its sensitivity, including encrypted connections to the Site, access controls that limit who can view form submissions, and contractual obligations on our service providers. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we become aware of a breach that affects your personal information, we will notify you and any regulator as required by applicable law.

Depending on where you live, you may have the right to ask us to confirm whether we hold personal information about you; to access it and receive a copy; to correct inaccurate or incomplete information; to delete it; to restrict or object to certain processing; to receive it in a portable format; and to withdraw consent. You may also have the right to lodge a complaint with a supervisory authority.

Redox Medical Group is a California business. This section is our notice at collection under the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA"). In the twelve months before the effective date we collected the following categories of personal information from practitioners who use the Site: identifiers (name, email address, telephone number, IP address); professional information (your stated intent to request access or join the waitlist, and any credentials you volunteer by email); and internet activity (server log data described in section 2). We collect this information directly from you and from your device, for the business purposes described in section 3, and we keep it for the periods described in section 6.

We do not sell personal information, we do not share it for cross-context behavioural advertising, and we do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA. We have not sold or shared personal information in the preceding twelve months, and we do not knowingly sell or share the personal information of consumers under sixteen.

As a California resident you have the right to know what personal information we collect, use, disclose and share; to access it and receive a copy; to correct inaccurate information; to delete it, subject to the exceptions in the CCPA; to limit the use of sensitive personal information; and to be free from discrimination for exercising these rights. To make a request, email [email protected] with "CCPA request" in the subject line, or call (310) 421-2707. We will verify your request against the details you gave us and respond within forty-five days, extending once by a further forty-five days where the law allows. You may authorise an agent to act for you; we will ask for written proof of that authority and may ask you to confirm your identity directly. Under California Civil Code section 1798.83 (the "Shine the Light" law) you may also ask whether we have disclosed personal information to third parties for their direct marketing purposes; we have not.

Residents of other U.S. states with comprehensive privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas and Oregon) have similar rights to access, correct, delete and port their data and to opt out of sales, targeted advertising and profiling. We honour those rights through the same contact channel, and you may appeal a refused request by replying to our decision.

Residents of the European Economic Area, the United Kingdom and Switzerland. The Site is operated from the United States. If you submit information from one of these regions, it will be transferred to and processed in the United States, where data protection laws may differ from those in your country. We take the steps required by applicable law to protect information in those transfers.

To exercise any of these rights, contact us at [email protected]. We will verify your identity using the details you provided in your submission and respond within the time required by applicable law, normally within thirty days. There is no charge for a reasonable request.

Do Not Track and Global Privacy Control. Because the Site does not track visitors across other websites, there is nothing for a Do Not Track or Global Privacy Control signal to switch off. We treat such signals as a request not to sell or share personal information, which is already our practice.

The Site is intended for licensed healthcare practitioners and is not directed to anyone under eighteen. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us and we will delete it.

The Site's form collects business contact details from practitioners; it is not designed to collect protected health information as defined by the Health Insurance Portability and Accountability Act (HIPAA). Where Redox or its partners handle protected health information in the course of dispensing or delivering prescribed products, that handling is governed by HIPAA, by the agreements between the practitioner, the pharmacy and Redox, and by the privacy notices those organisations provide, not by this policy.

The Site may link to websites operated by others, such as regulatory bodies or our partners. We are not responsible for the privacy practices or content of those sites, and this policy does not apply to them.

We may update this Privacy Policy from time to time. When we do, we will change the effective date at the top of the page and, where the change is material, we will notify practitioners who have submitted the form by email before the change takes effect. Continued use of the Site after a change means you accept the updated policy.

Questions, requests or complaints about this Privacy Policy or our handling of your information can be sent to the addresses below. Please include "Privacy" in the subject line of an email so that we can route your message quickly.

Redox Medical Group, 9100 Wilshire Blvd. Ste. 700W, Beverly Hills, CA 90212 · [email protected] · (310) 421-2707