Consumer Health Data Privacy Notice
Effective Date: 22nd July 2025Overview
Doceree Inc. ("Doceree," "we," "our," or "us") is committed to the responsible handling of personal information, including Consumer Health Data ("CHD") as defined under applicable U.S. state privacy laws. This Consumer Health Data Privacy Notice ("Notice") provides transparency about how we collect, use, and share CHD through our Co‑Pay Platform—a digital platform that allows individuals to access prescription savings offers and enables life sciences companies to operate manufacturer-sponsored co‑pay programs.
This Notice supplements the Doceree's Privacy Policy and applies only to data collected in a consumer context that qualifies as CHD under state-specific privacy laws, such as the Washington My Health My Data Act ("MHMDA"), Nevada Senate Bill 370, and similar statutes in other jurisdictions. It does not apply to data governed by HIPAA or similar healthcare privacy laws unless otherwise specified.
By accessing or using the Co‑Pay Platform, or by submitting any personal information that may constitute CHD, you acknowledge and agree to the practices described in this Notice.
Applicability
This applies only to Consumer Health Data that Doceree collects or processes via the Co‑Pay Platform in a personal consumer context. It does not apply to data collected in the course of employment, business-to-business engagements, or pursuant to a contract governed by HIPAA or other federal healthcare privacy laws.
By accessing or using the Co‑Pay Platform, you acknowledge that you have read and understand this. Your use of the Co-Pay Platform constitutes your agreement to the terms described herein.
What is Consumer Health Data?
For purposes of this Notice, "Consumer Health Data" (or "CHD") means any personal information that is linked or reasonably linkable to an identified or identifiable individual and that identifies or is used to infer aspects of the individual's health status. This includes information related to health conditions, diagnoses, medical treatments, medications, health-related behaviors, biometric or genetic information collected for health purposes, or other data elements when used in a context that suggests a health-related intention or activity.
Consumer Health Data also includes inferences drawn from behavioral or contextual data, for example, searching for certain medication names, viewing content about specific health conditions, or interacting with co‑pay offers for chronic or acute conditions, when such inferences reveal or are reasonably used to indicate health-related interests or needs.
Importantly, Doceree does not treat anonymized, aggregated, or de-identified information as Consumer Health Data, nor does this Notice apply to such data when maintained in a form that cannot reasonably identify an individual.
How We Collect Consumer Health Data
Doceree collects Consumer Health Data in the following ways:
- Directly from you: when you search for or view prescription offers, use features that relate to medications or health-related conditions, or voluntarily enter information to retrieve co‑pay coupons or educational resources.
- From third parties: including pharmaceutical manufacturers, pharmacies, coupon fulfillment vendors, and pharmacy benefit management systems, where permitted by law and required to operate or validate participation in co‑pay programs.
- Automatically: through your interactions with the Co‑Pay Platform, such as through session logs, cookies, device identifiers, clickstream analytics, and other digital tools that may suggest or infer health-related interests, depending on your behavior and preferences.
In all cases, Doceree limits collection of Consumer Health Data to the minimum necessary to provide the Co‑Pay Platform's core functionality, maintain user experience, improve service quality, and ensure operational compliance with legal and industry standards.
How We Use Consumer Health Data
Doceree uses Consumer Health Data only for purposes consistent with the delivery and improvement of the Co‑Pay Platform. This includes:
- Enabling access to prescription discount offers tailored to your inquiry;
- Facilitating delivery and redemption of manufacturer-sponsored co‑pay assistance;
- Customizing and improving the relevance of content presented to you;
- Validating eligibility for discounts in accordance with applicable program terms;
- Ensuring security, integrity, and availability of the Co-Pay Platform; and
- Conducting analytics, research, or optimization to improve affordability and access tools.
Doceree does not use Consumer Health Data for profiling in furtherance of decisions that produce legal or similarly significant effects. We also do not use Consumer Health Data to make automated decisions that affect your access to medications, benefits, or pricing without human oversight.
We do not sell Consumer Health Data and do not share it with third parties for unrelated advertising, marketing, or secondary monetization purposes.
How We Share Consumer Health Data
Doceree discloses Consumer Health Data only under limited circumstances and in accordance with applicable law:
- To our contracted service providers: who assist in operating the Co‑Pay Platform (such as hosting, analytics, fulfillment, or security vendors), under agreements that strictly limit how data may be used or disclosed;
- To pharmaceutical manufacturers or their authorized partners: but only in connection with your use of their co‑pay programs, and only to the extent necessary to support fulfillment, eligibility verification, compliance, or audit functions;
- To pharmacies or pharmacy benefit entities: where required to administer your participation in co‑pay offers;
- To our affiliates: in a manner consistent with this Notice and applicable law;
- To legal authorities, government agencies, courts, or regulators: where we are required to do so by law, subpoena, legal process, or to enforce our rights or investigate suspected misuse or fraud;
- In the context of a merger, acquisition, financing, or other business transaction: subject to appropriate confidentiality and legal safeguards.
- We do not authorize third parties to use CHD obtained from Doceree for independent commercial purposes, nor do we permit behavioral advertising using CHD, unless such use is explicitly permitted by you and by law.
Your Rights and Choices
Depending on your state of residence, you may have certain rights under applicable U.S. Consumer Health Data privacy laws. These rights may include:
- The right to confirm whether we are collecting or processing your Consumer Health Data;
- The right to access or obtain a copy of your Consumer Health Data;
- The right to request deletion of your Consumer Health Data, subject to legal retention requirements;
- The right to request correction of inaccurate or outdated Consumer Health Data;
- The right to withdraw your consent (if consent was the legal basis for collection); and
- The right to appeal a denial of your request.
To exercise these rights, or to request information about our Consumer Health Data practices, please email us at: privacy@doceree.com. When submitting a request, please provide sufficient detail to allow us to understand, evaluate, and respond appropriately. We may need to verify your identity before processing your request, and we will respond in accordance with the applicable legal timeframes. If your request is denied, you have the right to appeal the decision by contacting us through the same channels.
Data Retention and Security
Doceree retains Consumer Health Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. We use a combination of technical, administrative, and physical safeguards to protect the confidentiality, integrity, and availability of Consumer Health Data, including encryption, access controls, monitoring, and regular risk assessments.
We do not retain Consumer Health Data indefinitely and implement internal policies for disposal, anonymization, or de-identification of such data when no longer needed.
Updates to This Notice
We may update this Notice from time to time in response to legal changes, technological developments, or modifications to our practices. If we make material changes, we will revise the "Last Updated" date at the top and may notify you through the Co-Pay Platform or other appropriate channels.
Continued use of the Co‑Pay Platform following such updates constitutes your acceptance of the revised Notice, to the extent permitted by law.
Contact Information
For questions, data requests, or appeals, please contact:
Doceree Inc
Attn: Legal Department
150 John F Kennedy Parkway, Suite 403
Short Hills, NJ 07078