ADEGEN LLC

CONSUMER HEALTH DATA PRIVACY POLICY

Effective Date: July 1, 2026

This Consumer Health Data Privacy Policy ("CHDPP") supplements our Privacy Policy and applies specifically to Consumer Health Data collected by Adegen LLC ("Adegen," "we," "us," or "our") through the adegen.com website (the "Site") and our Services. This policy is intended to provide transparency about how we collect, use, and share health-related information that does not constitute protected health information ("PHI") under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA").

This policy is designed to address requirements under Washington State's My Health MY Data Act and similar consumer health data privacy laws enacted or proposed in other states. Even if you do not reside in Washington State, we apply these practices to all users of our Site as a matter of good practice.

If there is a conflict between this CHDPP and our general Privacy Policy, this CHDPP controls with respect to Consumer Health Data.

1. WHAT IS CONSUMER HEALTH DATA

"Consumer Health Data" means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. For purposes of this policy, Consumer Health Data collected by Adegen may include:

• Information you provide in our hair loss assessment or intake questionnaire, such as the extent and duration of your hair loss, family history of hair loss, current medications, and general health status

• Information about your interest in or use of specific hair loss treatments, including prescription and over-the-counter products

• Health-related browsing activity on the Site, such as pages you visit related to specific treatment categories, ingredients, or conditions

• Photos of your hair or scalp that you submit as part of an intake or consultation process

• Information derived or inferred from the above that relates to your health status or treatment preferences

Consumer Health Data does not include information that has been de-identified in accordance with applicable law such that it cannot reasonably be used to identify you.

Consumer Health Data collected by Adegen in its capacity as a telehealth platform facilitator is distinct from protected health information (PHI) maintained by Providers or the applicable licensed pharmacy in connection with your clinical care. PHI in the hands of those entities is governed by their respective Notice of Privacy Practices and applicable healthcare privacy laws.

2. CONSUMER HEALTH DATA WE COLLECT

2.1 Data You Provide Directly

We collect Consumer Health Data that you voluntarily provide when you:

• Complete our hair loss assessment questionnaire

• Submit photos of your hair or scalp through the Site

• Provide information about your current medications, health conditions, or medical history in connection with an intake form

• Communicate with our customer support team about health-related questions or treatment concerns

• Participate in surveys or research initiatives related to hair loss or our products

2.2 Data Collected Automatically

We may collect Consumer Health Data automatically through your use of the Site, including:

• Pages you visit that are associated with specific health conditions, treatments, or product categories (for example, visiting a page specifically about finasteride or dutasteride may indicate an interest in DHT-blocking treatments)

• Search queries you enter on the Site that relate to health conditions or treatments

• Clicks, interactions, and time spent on health-related content

• Information collected through cookies and similar tracking technologies when you engage with health-related content on the Site

Please see Section 4 of our Privacy Policy for more detail on cookies and tracking technologies.

2.3 Data Received from Third Parties

We may receive limited Consumer Health Data from third-party sources, such as advertising platforms that provide audience segmentation data indicating general health interests. We do not purchase detailed individual health records from data brokers.

3. HOW WE USE CONSUMER HEALTH DATA

We use Consumer Health Data only for the following purposes:

• To facilitate your access to telehealth consultations with independent licensed Providers by transmitting your intake information to the applicable Provider

• To match you with product and treatment options that may be appropriate based on your disclosed health profile

• To personalize the content, recommendations, and user experience you receive on the Site

• To improve our Services, products, and intake processes

• To communicate with you about your account, orders, and treatment-related information

• To comply with applicable legal obligations

• To detect and prevent fraud or misuse of our Services

We do not use Consumer Health Data to make automated decisions that produce legal or similarly significant effects without human review.

We do not use Consumer Health Data collected through the Site for targeted advertising based on your specific health conditions or treatment history without your express consent.

4. HOW WE SHARE CONSUMER HEALTH DATA

We share Consumer Health Data only in the following circumstances:

4.1 With Your Authorization

When you initiate a telehealth consultation, you authorize us to share your Consumer Health Data, including your intake questionnaire responses and any photos you submit, with the applicable independent licensed Provider(s) for the purpose of facilitating your consultation. If a prescription is issued, you authorize us to share necessary information with the applicable licensed pharmacy for prescription fulfillment purposes. This sharing occurs only after you have affirmatively agreed to our Telehealth Consent.

We will not share your Consumer Health Data for any other purpose without your express, informed consent, except as described in this policy.

4.2 With Service Providers

We share Consumer Health Data with a limited set of trusted third-party service providers who assist us in operating the Site and delivering our Services. These providers include:

• Technology and hosting infrastructure providers

• Customer support and communication platforms

• Analytics platforms, subject to data processing agreements that limit use of health-related data

All service providers who receive Consumer Health Data are contractually prohibited from using it for their own independent purposes and are required to implement appropriate security measures.

4.3 Legal Requirements and Safety

We may disclose Consumer Health Data if required by law, court order, or governmental process, or if we reasonably believe disclosure is necessary to prevent imminent harm to you or others.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of our assets, Consumer Health Data may be transferred to the acquiring entity, subject to the same protections described in this policy. We will provide notice of any such transfer.

4.5 What We Do Not Do

We do not:

• Sell your Consumer Health Data to third parties

• Share your Consumer Health Data with employers, insurance companies, or financial institutions

• Share your Consumer Health Data with data brokers

• Use your Consumer Health Data for targeted advertising based on your specific health conditions without your express consent

• Disclose your Consumer Health Data to law enforcement without a valid legal process, except in cases of imminent danger

5. YOUR RIGHTS REGARDING CONSUMER HEALTH DATA

Subject to applicable law, you have the following rights with respect to your Consumer Health Data:

5.1 Right to Access

You have the right to request a copy of the Consumer Health Data we hold about you, including the categories of data collected, the purposes for which it is used, and the third parties with whom it has been shared.

5.2 Right to Correction

You have the right to request that we correct inaccurate Consumer Health Data we hold about you.

5.3 Right to Deletion

You have the right to request that we delete your Consumer Health Data, subject to certain exceptions, including where we are required by law to retain it or where retention is necessary to complete a transaction you initiated.

5.4 Right to Withdraw Consent

Where our use of your Consumer Health Data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing conducted prior to withdrawal but may affect our ability to continue providing certain Services to you.

5.5 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights. We will not deny you products or Services, charge you different prices, or provide you a different level of quality because you exercised a right described in this policy.

5.6 How to Submit a Request

To exercise any of the rights described above, please contact us at support@adegen.com with the subject line "Consumer Health Data Request." Please include your full name, the email address associated with your account, and a description of your request. We will respond within the timeframe required by applicable law, typically within 45 days, with a possible extension of an additional 45 days where reasonably necessary.

We may need to verify your identity before processing your request. We will not use information you provide for verification purposes for any other purpose.

6. DATA SECURITY FOR CONSUMER HEALTH DATA

We apply heightened security measures to Consumer Health Data, including:

• Encryption of Consumer Health Data in transit and at rest

• Access controls limiting access to Consumer Health Data to personnel and systems with a legitimate need

• Regular review of data handling practices and vendor security standards

• Contractual data protection requirements imposed on all service providers who handle Consumer Health Data

Despite these measures, no system is completely secure. If you believe your Consumer Health Data has been compromised, please contact us immediately at support@adegen.com.

7. RETENTION OF CONSUMER HEALTH DATA

We retain Consumer Health Data for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required by law. Intake questionnaire responses are retained for the duration of your account and for a reasonable period thereafter to support any follow-up consultations or customer service needs. You may request deletion of your Consumer Health Data at any time as described in Section 5.3.

8. GEOFENCING PROHIBITION

We do not use geofencing technology to collect or use Consumer Health Data around healthcare facilities, including pharmacies, clinics, or medical offices.

9. CHANGES TO THIS POLICY

We may update this Consumer Health Data Privacy Policy from time to time. When we make material changes, we will update the Effective Date and, where required by law, obtain your consent before applying the new practices to previously collected data. We encourage you to review this policy periodically.

10. CONTACT US

For questions, concerns, or requests related to this Consumer Health Data Privacy Policy, please contact us at:

Adegen LLC

30 N Gould St, Ste R

Sheridan, WY 82801

Email: support@adegen.com

Subject line: Consumer Health Data Request

Last Updated: July 1, 2026