Privacy Policy
ADEGEN LLC
PRIVACY POLICY
Effective Date: July 1, 2026
Adegen LLC ("Adegen," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at adegen.com (the "Site") or use any of our products or services (collectively, the "Services").
Please read this Privacy Policy carefully. This Privacy Policy describes how we collect, use, disclose, and protect your information. By using the Site or Services, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to process certain categories of information, we will obtain that consent separately through the applicable consent mechanism.
This Privacy Policy applies to information collected by Adegen LLC as a platform and retailer. It does not govern the handling of protected health information ("PHI") by healthcare providers or the applicable licensed pharmacy in connection with your medical care. For information on how your PHI is handled in connection with telehealth consultations, please review the Notice of Privacy Practices provided by the applicable Provider or pharmacy, which is linked separately on our Site.
Adegen LLC is not a covered entity under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA").
1. INFORMATION WE COLLECT
We collect information in several ways depending on how you interact with the Site and Services.
1.1 Information You Provide Directly
We collect information you provide when you:
• Create an account (name, email address, password, date of birth)
• Complete an intake questionnaire or hair loss assessment (responses to health and lifestyle questions)
• Initiate a telehealth consultation (health history, current medications, photos of hair loss)
• Make a purchase (billing address, shipping address, payment information)
• Contact our customer support team (communications, feedback, inquiries)
• Subscribe to our email or SMS marketing list (email address, phone number)
• Participate in surveys, promotions, or referral programs
1.2 Information Collected Automatically
When you visit the Site, we and our service providers automatically collect certain technical information, including:
• Device information: IP address, browser type and version, operating system, device identifiers
• Usage data: pages visited, time spent on pages, referring URLs, links clicked, search terms used on the Site
• Location data: general geographic location inferred from IP address
• Cookie and tracking data: as described in Section 4 below
1.3 Information from Third Parties
We may receive information about you from third parties, including:
• Payment processors (transaction confirmation, fraud signals)
• Advertising and analytics partners (audience data, campaign performance)
• Affiliate partners (referral source tracking)
• Social media platforms, if you interact with our content or log in via a social account
We do not receive your protected health information from Providers or the Pharmacy for marketing purposes.
1.4 Information Collected Through Our Intake Questionnaire
Our hair loss assessment and intake questionnaire collects health-related information prior to any clinical relationship being established. This may include information about your hair loss history, family history, current medications, and general health status. This pre-clinical data is used to facilitate your access to telehealth services and to match you with appropriate treatment options. Please also review our Consumer Health Data Privacy Policy for additional disclosures regarding this category of information.
2. HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
2.1 Providing and Improving the Services
• Create and manage your account
• Process and fulfill your orders for products and services
• Facilitate telehealth consultations with Providers
• Transmit relevant intake information to Providers and the Pharmacy as necessary to provide Services
• Communicate with you about your orders, treatment status, and account
• Respond to your questions and customer support requests
• Improve the Site, Services, and user experience
2.2 Marketing and Communications
• Send you promotional emails about new products, offers, and content, with your consent
• Send you SMS messages regarding your account, orders, or promotions, with your consent
• Personalize the content and recommendations you see on the Site
• Measure the effectiveness of our marketing campaigns
You may opt out of promotional email communications at any time by clicking the unsubscribe link in any promotional email. You may opt out of promotional SMS messages by replying STOP to any such message. Opting out of marketing communications will not affect transactional or account-related communications.
2.3 Analytics and Site Performance
• Monitor and analyze usage patterns and trends
• Diagnose technical issues and improve Site reliability
• Conduct research and analysis to better understand our customers
2.4 Legal and Compliance
• Comply with applicable laws, regulations, and legal processes
• Detect, investigate, and prevent fraud or other illegal activity
• Enforce our Terms of Service and other agreements
• Protect the rights, property, and safety of Adegen, our users, and the public
3. HOW WE SHARE YOUR INFORMATION
We do not sell your personal information to third parties for their own independent marketing purposes. We may share your information in the following circumstances:
3.1 Service Providers and Vendors
We share information with trusted third-party vendors who perform services on our behalf, including:
• Payment processors (to process transactions)
• Shipping and fulfillment partners (to deliver your orders)
• Email and SMS communication platforms (to send account and marketing communications)
• Analytics and advertising platforms (to measure Site performance and campaign effectiveness)
• Customer relationship management and support platforms
• Website hosting and infrastructure providers
• Subscription management platforms
We do not sell personal information for money. We may disclose limited personal information to analytics, advertising, and similar partners for the purposes described in this Privacy Policy, including to measure the effectiveness of our marketing campaigns and to deliver relevant advertising. Where required by applicable law, including the California Consumer Privacy Act and similar state privacy laws, you may have the right to opt out of such sharing or targeted advertising. See Section 9 for information on how to exercise your privacy rights.
These vendors are contractually obligated to use your information only as directed by us and in accordance with this Privacy Policy.
3.2 Providers and Pharmacy
When you initiate a telehealth consultation, we share the information you provide in your intake questionnaire and account with the applicable independent licensed Provider(s) to facilitate your consultation. If a prescription is issued, we share necessary information with the applicable licensed pharmacy to process and fulfill your prescription. This sharing occurs only after you have initiated the telehealth process and affirmatively agreed to our Telehealth Consent, and is done solely to facilitate your care.
3.3 Affiliate and Referral Partners
If you arrive at our Site through an affiliate or referral link, we may share limited information (such as whether a purchase was made) with that affiliate partner for the purpose of calculating and paying commissions. We do not share health information with affiliate partners.
3.4 Business Transfers
In the event of a merger, acquisition, sale of assets, bankruptcy, or other business transaction, your information may be transferred to the acquiring entity. We will provide notice of any such transfer and any material changes to this Privacy Policy.
3.5 Legal Requirements
We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect the rights, property, or safety of Adegen, our users, or others.
3.6 With Your Consent
We may share your information with third parties when you have given us your express consent to do so.
4. COOKIES AND TRACKING TECHNOLOGIES
4.1 What We Use
We use cookies, pixel tags, web beacons, and similar tracking technologies on the Site to:
• Keep you logged in to your account
• Remember your preferences and settings
• Analyze Site traffic and user behavior (via tools such as Google Analytics)
• Deliver and measure the effectiveness of advertising campaigns
• Support our affiliate and referral tracking program
4.2 Types of Cookies
Essential cookies: Required for the Site to function. These cannot be disabled.
Functional cookies: Remember your preferences to improve your experience.
Analytics cookies: Help us understand how visitors interact with the Site.
Advertising cookies: Used to deliver relevant ads and track campaign performance.
4.3 Your Choices
You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Note that disabling certain cookies may affect Site functionality. You may also opt out of interest-based advertising through the Digital Advertising Alliance at www.aboutads.info or the Network Advertising Initiative at www.networkadvertising.org.
To opt out of Google Analytics tracking, visit https://tools.google.com/dlpage/gaoptout.
5. SMS COMMUNICATIONS
If you provide your mobile phone number and opt in to receive SMS messages from us, we will use your number to send:
• Order confirmations, shipping updates, and account notifications
• Reminders related to your treatment or subscription
• Promotional offers and new product announcements (only with your express consent)
Message frequency will vary. Standard message and data rates may apply. You may opt out at any time by replying STOP to any SMS message from us. For help, reply HELP.
We do not sell, rent, or share your mobile phone number or SMS consent with third parties for their own marketing purposes.
6. DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Factors we consider include:
• Whether you have an active account with us
• Whether we have a legal obligation to retain the data (e.g., tax records, transaction records)
• Whether retention is necessary to resolve disputes or enforce our agreements
When we no longer need your information, we will securely delete or anonymize it. Note that healthcare Providers and the Pharmacy may be subject to separate, longer retention requirements under applicable healthcare laws and professional regulations.
7. DATA SECURITY
We implement commercially reasonable technical, administrative, and physical security measures designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit using TLS/SSL, access controls, and vendor security requirements.
However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information. If you have reason to believe that your account has been compromised, please contact us immediately at support@adegen.com.
8. CHILDREN'S PRIVACY
The Site and Services are intended for adults who are 18 years of age or older. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected information from a minor, we will take prompt steps to delete it. If you believe we have collected information from a minor, please contact us at support@adegen.com.
9. YOUR PRIVACY RIGHTS
9.1 Access, Correction, and Deletion
Subject to applicable law, you may have the right to:
• Access the personal information we hold about you
• Correct inaccurate or incomplete personal information
• Request deletion of your personal information, subject to certain exceptions
• Request that we restrict or limit our use of your personal information
• Receive a copy of your personal information in a portable format
To exercise any of these rights, please contact us at support@adegen.com. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.
9.2 California Residents
If you are a California resident, you may have additional rights under the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of the sale or sharing of your personal information. We do not sell personal information as that term is defined under the CCPA/CPRA.
California residents may also have rights under California Civil Code Section 1798.83 (Shine the Light law) regarding the sharing of personal information with third parties for direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.
For health-related data collected through our intake questionnaire or site interactions prior to a clinical relationship being established, please also review our Consumer Health Data Privacy Policy, which provides additional disclosures and rights specific to that category of information.
9.3 Other State Privacy Laws
Residents of certain other states, including Virginia, Colorado, Connecticut, Texas, and others with comprehensive privacy laws, may have similar rights to access, correct, delete, and opt out of certain processing of their personal information. To submit a request, please contact us at support@adegen.com.
10. DO NOT TRACK
Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. Because there is no uniform standard for interpreting DNT signals, the Site does not currently respond to DNT signals. We will reassess this position as industry standards evolve.
11. THIRD-PARTY LINKS
The Site may contain links to third-party websites, including the platforms of our Provider and Pharmacy partners, social media platforms, and other external sites. This Privacy Policy does not apply to third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices of third parties.
12. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the Effective Date at the top of this page and, where appropriate, notify you by email or by a notice on the Site. Your continued use of the Site after any update constitutes your acceptance of the revised Privacy Policy.
13. HIPAA AND PROTECTED HEALTH INFORMATION
Adegen LLC is not a covered entity or business associate under HIPAA in its capacity as a telehealth platform and retailer. The personal information you provide to Adegen through the Site is not considered protected health information (PHI) under HIPAA when maintained and used by Adegen for platform and retail purposes.
When you initiate a telehealth consultation, health information you provide may be transmitted to independent licensed Providers and to the applicable licensed pharmacy. Those entities may be covered entities or otherwise subject to applicable health information privacy laws. Your PHI in the hands of those entities is governed by their respective Notice of Privacy Practices, which is available at https://privacy.mdintegrations.com.
14. CONTACT US
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Adegen LLC
30 N Gould St, Ste R
Sheridan, WY 82801
Email: support@adegen.com
We will respond to privacy-related inquiries within a reasonable timeframe and in accordance with applicable law.
Last Updated: July 1, 2026