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BetterSkin · Legal

Privacy Policy

Effective Date: June 18, 2026 | Last Revised: September 10, 2026

BetterSkin Group, LLC | www.betterskin.com

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INTRODUCTIONSECTION 1: INFORMATION WE COLLECT1.1 Information You Provide Directly1.2 Information We Collect Automatically1.3 Information From Third PartiesSECTION 2: HOW WE USE YOUR INFORMATIONSECTION 3: HOW WE DISCLOSE YOUR INFORMATIONSECTION 4: TRACKING TECHNOLOGY, ADVERTISING, AND YOUR CHOICES4.1 Our Three-Zone Data Architecture4.2 Cookies and Consent4.3 Patient Imagery in Marketing4.4 Email Marketing4.5 SMS MarketingSECTION 5: YOUR RIGHTS AND CHOICESSECTION 6: ANALYTICS PRACTICESSECTION 7: HOW WE PROTECT YOUR INFORMATIONSECTION 8: CHILDRENSECTION 9: ADDITIONAL STATE-SPECIFIC RIGHTS9.1 California Residents9.2 Nevada Residents9.3 Washington, Connecticut, and Nevada Consumer Health DataSECTION 10: RETENTIONSECTION 11: CHANGES TO THIS POLICYSECTION 12: CONTACT US

INTRODUCTION

BetterSkin Group, LLC ("BetterSkin," "we," "us," or "our") owns and operates www.betterskin.com and any associated applications (the "Services"). This Privacy Policy describes how we collect, use, and disclose your information and explains your rights with respect to that information.

BetterSkin operates a telehealth dermatology platform and an over-the-counter skincare storefront. Because we operate across both of these categories, this Privacy Policy addresses our practices with specificity — including how our data practices differ between our public marketing site, our over-the-counter shop, and our clinical and telehealth flows. These distinctions matter for your rights and our legal obligations, and we describe them plainly below.

This Privacy Policy is incorporated into our Terms of Use. If you have questions, contact us at compliance@betterskin.com.

SECTION 1: INFORMATION WE COLLECT

1.1 Information You Provide Directly

We collect information you provide when you create an account, complete a patient intake form, schedule or attend a telehealth visit, purchase a product, or contact us for support. This includes:

  • Identifiers: name, email address, phone number, date of birth, mailing address;
  • Billing information: collected by our payment processors on our behalf;
  • Health information: skin conditions, symptoms, medical history, medications, allergies, photos and video you submit, and information about your skincare routine and lifestyle;
  • Identity verification information: driver's license or government-issued ID, where required;
  • Communications: messages you send through the platform, including messages to your provider; and
  • Account credentials: username and password.

1.2 Information We Collect Automatically

When you visit our public marketing site or over-the-counter shop, we may collect certain information automatically, subject to your consent choices as described in Section 4 below. This includes:

  • IP address and general location (city, state, ZIP code);
  • Device identifiers and browser type;
  • Pages visited, time spent, and referral source; and
  • Cookie and similar tracking technology data.

IMPORTANT: No third-party advertising or analytics tags, pixels, session-replay tools, or tracking scripts fire on any authenticated page, clinical page, telehealth flow, or patient intake form. These tracking technologies are restricted to our public marketing site and over-the-counter shop, and only with your affirmative consent. See Section 4 for details.

1.3 Information From Third Parties

We may receive information about you from our affiliated healthcare providers, our partner pharmacy in connection with prescription fulfillment, and social media platforms if you interact with our content. We may also receive general marketing data from advertising partners, subject to the limitations described in Section 4.

SECTION 2: HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

  • Providing and managing the Services: Delivering telehealth consultations, processing orders, managing your account, communicating with you about your care, and facilitating prescription fulfillment through our partner pharmacy.
  • Healthcare operations: Quality assessment, provider credentialing, compliance, and internal operations that support the provision of healthcare.
  • Analytics and improvement: Understanding how the Services are used, improving our products and platform, and conducting research using de-identified or aggregate data.
  • Marketing and advertising: Sending you information about our products and services, and delivering relevant advertising on our public marketing site, subject to your consent choices and the restrictions described in Section 4.
  • Legal purposes: Complying with applicable law, responding to legal process, and establishing, exercising, or defending our legal rights.

Email marketing segmentation. We do not segment marketing emails by skin condition, prescribed product, or telehealth consult status. We segment general marketing communications on non-health signals such as sign-up date, engagement history, general shop purchase history, geography, and source campaign. Appointment reminders, clinical follow-up, shipping updates, and care-coordination communications are not marketing and are sent separately under our HIPAA obligations.

SECTION 3: HOW WE DISCLOSE YOUR INFORMATION

Affiliated healthcare providers and physician practices. We share your information with the licensed healthcare providers and affiliated physician practices that deliver your care, for treatment, payment, and healthcare operations purposes.

Partner pharmacy. If your provider issues a prescription, we share the relevant information with our partner pharmacy to fulfill and ship your prescription. Our partner pharmacy is a Business Associate under a signed Business Associate Agreement.

Service providers. We share information with vendors that perform services on our behalf, including technology platforms, payment processors, and customer support services. All vendors that handle protected health information operate under signed Business Associate Agreements. Vendors that handle non-health personal information are bound by data processing agreements requiring appropriate protections.

Telehealth platform. We use Healee, operated by Eight Investments Inc., as our telehealth technology platform. Eight Investments Inc. is a Business Associate under a signed Business Associate Agreement effective June 15, 2026. Healee processes protected health information solely to provide the telehealth platform services described in that agreement and does not use your health information for advertising or marketing purposes.

Advertising and analytics partners. On our public marketing site and over-the-counter shop only, and only with your affirmative consent, we may share limited technical data (such as cookie identifiers and general browsing behavior) with advertising and analytics partners for the purposes described in Section 4. We do not share health information, prescription data, intake responses, or any information derived from your clinical interactions with advertising partners.

We do not:

  • Build advertising audiences from patient lists, consult completers, or prescription purchasers;
  • Upload customer lists derived from health signals or clinical activity to advertising platforms;
  • Build retargeting audiences from intake questionnaire behavior, including individuals who began but did not complete an intake;
  • Link our analytics accounts to advertising platforms in a way that allows health-linked data to flow between them; or
  • Use hashed identifiers derived from health signals as advertising match keys.

Protection of BetterSkin and others. We may disclose information as required by law, in response to legal process, or to protect the rights, property, or safety of BetterSkin, its providers, its users, or the public.

Business transfers. In connection with a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

With your consent. We may disclose your information in other ways you direct us to and when we have your specific consent, including for uses of patient photos or imagery in marketing as described in Section 4.3.

SECTION 4: TRACKING TECHNOLOGY, ADVERTISING, AND YOUR CHOICES

4.1 Our Three-Zone Data Architecture

BetterSkin operates a three-zone data architecture that governs what tracking technology may be present on different parts of our platform:

Zone A — Public Marketing Site: Homepage, editorial content, brand pages, over-the-counter shop browsing, and general informational pages. Third-party analytics and advertising tags may be present in this zone, blocked by default and activated only with your affirmative consent.

Zone B — Transitional Pages: Condition education pages, pricing pages, and pre-intake landing pages. Consent-gated tags only. No condition, treatment, or product name appears in any URL, page title, or URL parameter that a tag could read.

Zone C — Clinical and Authenticated Pages: Patient intake questionnaire (from the first question), telehealth consultation, provider match, prescription status, account pages, order history, and all Healee-hosted flows. No third-party advertising or analytics tags. No exceptions. BAA-covered server-side telemetry only.

4.2 Cookies and Consent

On Zone A and Zone B pages, we use cookies and similar tracking technologies for analytics and advertising purposes. All such tags are blocked by default. They activate only after you provide affirmative opt-in consent through our consent management platform. You may withdraw consent at any time through the "Your Privacy Choices" link available on our website.

We honor the Global Privacy Control (GPC) browser signal. If your browser or device transmits a GPC signal, we treat it as a request to opt out of the sale or sharing of your personal information for targeted advertising, and we will not activate advertising tags on your session regardless of any other consent state.

The following types of tracking are not used on BetterSkin:

  • Session replay, heatmap, or scroll-recording tools on any page beyond the public marketing site;
  • Any tag or pixel on the patient intake questionnaire, at any step;
  • Any tag or pixel on authenticated pages, clinical pages, or Healee-hosted flows;
  • Condition, product, or symptom information in any URL, page title, query parameter, or form field name readable by a tracking tool; and
  • Google Analytics linked to Google Ads, Google Signals, or any advertising destination for properties that include health-related pages.

4.3 Patient Imagery in Marketing

BetterSkin does not use patient photos, videos, or before-and-after imagery in any marketing, advertising, or promotional material without a signed HIPAA Authorization from the patient specifically authorizing that use. Informal permission, including a direct message or verbal agreement, is not a valid authorization under HIPAA. Any authorization for marketing use of patient imagery must name the specific use (website, paid advertising, social media, or other) and be retained on file. If you have questions about imagery authorizations, contact compliance@betterskin.com.

4.4 Email Marketing

We do not include third-party advertising platform tracking pixels in our marketing emails. Our email service provider operates under a data processing agreement that prohibits the use of your email data for advertising purposes outside our own campaigns. We do not sync patient lists or prescription customer lists to advertising platform audience tools.

We use our email service provider's own open and click tracking for the purpose of measuring campaign performance. This tracking operates under our data processing agreement with our email provider and does not result in disclosure to third-party advertising platforms.

4.5 SMS Marketing

BetterSkin does not sell, share, or otherwise disclose mobile phone numbers or SMS consent information to third parties for their own marketing purposes. Consent to receive appointment reminders, shipping notifications, or other transactional text messages from BetterSkin is separate from consent to receive marketing text messages. We will not send marketing SMS messages without your separate, prior express written consent obtained specifically for marketing SMS. Transactional messages include appointment confirmations and reminders, order and shipping updates, prescription status notifications, and provider communications. Marketing messages, where separately consented to, may include promotional offers, new product announcements, and skincare tips. Message frequency varies by message type and your level of activity on the platform.

You may revoke SMS consent at any time by replying STOP to any message from us, replying HELP for assistance, by emailing compliance@betterskin.com, or by any other reasonable means. We will honor all revocation requests within ten (10) business days across all of our messaging systems. We do not impose a single exclusive method for revoking SMS consent. Message and data rates may apply.

SECTION 5: YOUR RIGHTS AND CHOICES

Depending on where you live, you may have the following rights with respect to your personal information:

  • Access: request a copy of the personal information we hold about you;
  • Correction: request that we correct inaccurate information;
  • Deletion: request that we delete your information, subject to legal and operational retention requirements;
  • Opt out of sale or sharing: opt out of the sale or sharing of your personal information for targeted advertising;
  • Limit sensitive data use: limit our use of sensitive personal information beyond providing the services you requested; and
  • Portability: receive a copy of your information in a portable format.

To exercise any of these rights, visit www.betterskin.com/privacy-requests or email compliance@betterskin.com. We will verify your identity before processing your request and respond within the timeframe required by applicable law. If we deny your request, we will explain our reasons. Where required by law, you may appeal our decision.

To opt out of sale or sharing for targeted advertising, visit www.betterskin.com/do-not-sell or activate the Global Privacy Control signal on your browser or device.

SECTION 6: ANALYTICS PRACTICES

We do not run Google Analytics or other general-purpose analytics tools on any page where protected health information or patient intake data is present. We do not link our analytics accounts to advertising platforms in a way that allows health-linked data to flow between them.

All analytics involving clinical outcomes, provider performance, or patient-level data are conducted inside a BAA-covered environment. Only aggregated, de-identified metrics are exported from that environment for business reporting purposes. De-identification meets either the Expert Determination or Safe Harbor standard under 45 C.F.R. § 164.514.

We retain analytics data for no longer than necessary for the purposes for which it was collected, subject to legal retention requirements.

SECTION 7: HOW WE PROTECT YOUR INFORMATION

We implement administrative, physical, and technical safeguards appropriate to the sensitivity of the information we hold. Our telehealth platform, operated by our Business Associate Healee (Eight Investments Inc.), implements security safeguards required under the HIPAA Security Rule. Clinical data is processed in a BAA-covered environment and is not accessible to marketing or advertising systems.

No method of transmission over the internet or electronic storage is completely secure. If we discover a breach of your unsecured protected health information, we will notify you in accordance with the HIPAA Breach Notification Rule and any other applicable law.

SECTION 8: CHILDREN

Our Services are intended for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under the age of 13. We do not direct advertising to audiences that include individuals under the age of 18.

SECTION 9: ADDITIONAL STATE-SPECIFIC RIGHTS

9.1 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights, including the right to know what personal information we have collected about you over the past 12 months, the right to delete that information, the right to opt out of the sale or sharing of your personal information, the right to limit use of sensitive personal information, and the right to non-discrimination for exercising your rights.

We do not sell personal information in exchange for money. We do share certain technical identifiers with advertising partners for targeted advertising purposes on our Zone A pages, with your consent, which may qualify as "sharing" under the CCPA. You may opt out at www.betterskin.com/do-not-sell.

California's "Shine the Light" law permits California residents to request information about disclosures of personal information to third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

California's Consumer Privacy Act also requires us to disclose whether we knowingly sell or share the personal information of consumers under the age of 16. We do not.

9.2 Nevada Residents

Nevada law permits Nevada consumers to opt out of the sale of certain personal information to third parties for resale. We do not sell personal information in this manner. Nevada residents may submit an opt-out request to compliance@betterskin.com.

9.3 Washington, Connecticut, and Nevada Consumer Health Data

If you are a resident of Washington, Connecticut, or Nevada, please review our Consumer Health Data Privacy Policy at www.betterskin.com/consumer-health-data-privacy-policy for additional information about your rights with respect to consumer health data as defined under applicable state law.

SECTION 10: RETENTION

We retain personal information for no longer than necessary for the purposes for which it was collected, subject to applicable legal retention requirements. Medical records are retained in accordance with applicable state law and HIPAA. Marketing and analytics data is retained on a shorter schedule. You may request deletion of non-clinical personal information at any time.

SECTION 11: CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. If we make a material change, we will notify you by email or through a prominent notice on our website before the change becomes effective. The date this Policy was last revised appears at the top of this document. Your continued use of the Services after the effective date of a material change constitutes your acceptance of the revised Policy.

SECTION 12: CONTACT US

Privacy Officer, BetterSkin Group, LLC

120 N Marina St Suite C, Prescott, AZ 86301

compliance@betterskin.com

www.betterskin.com/privacy-requests

For compliance and regulatory inquiries: compliance@betterskin.com

For general feedback: feedback@betterskin.com

BetterSkin Group, LLC | 120 N Marina St Suite C, Prescott, AZ 86301

compliance@betterskin.com | www.betterskin.com