We do not sell your personal information or your health information. We never use your health information for advertising.
1. Who this policy covers
This Privacy Policy applies to THINKR ("THINKR," "we," "us") and to information collected through thinkrmd.com, our assessments, accounts, emails and texts (the "Services"). It should be read together with our Terms of Service and Telehealth Consent.
2. Health information and HIPAA
When you receive care, the independent clinicians and pharmacies who treat you are "covered entities" under the Health Insurance Portability and Accountability Act (HIPAA). Health information they create or receive — such as your assessment answers, diagnoses, prescriptions and lab results — is protected health information ("PHI"). It is handled under their Notice of Privacy Practices and HIPAA.
Where THINKR handles PHI on behalf of those providers, we do so as a "business associate" under a written agreement that requires us to protect it and use it only as HIPAA allows. Where HIPAA and this policy differ for PHI, HIPAA controls.
3. Information we collect
Information you give us:
- Contact and account details: name, email, phone number, date of birth, shipping address and password.
- Health information: assessment answers, medical history, medications, allergies, measurements, photos or ID you upload, lab results and messages with clinicians.
- Payment details: billing name and address. Card numbers are collected and stored by our payment processor, not by us.
- Communications: messages to support, survey responses and feedback.
Information collected automatically: device and browser type, IP address, approximate location, pages viewed, links clicked and referring websites, collected through cookies and similar tools (see section 6).
Information from others: your clinicians, pharmacies and labs; identity-verification and payment providers; and sign-in providers (Google, Apple or Microsoft) if you choose to sign in with them, which share your name and email.
4. How we use information
- To provide the Services: create your account, connect you with clinicians, arrange prescriptions and shipping, and support you.
- To process payments and manage memberships.
- To communicate about your care, orders, account and changes to our policies.
- To keep the Services safe: verify identity, prevent fraud and misuse, and meet legal duties.
- To improve the Services using aggregated or de-identified information.
- To send optional marketing about THINKR, using only non-health information and only where the law allows. You can opt out anytime.
5. How we share information
We share information only as needed to run the Services or as the law requires:
- Clinicians, pharmacies and labs who provide your care.
- Service providers who host our site, process payments, send messages, verify identity or ship orders, under contracts that limit their use of your information (and, for PHI, business associate agreements).
- Legal and safety reasons: to comply with law, court orders or regulators, or to protect the safety of you or others.
- Business changes: to a successor in a merger, acquisition or sale of assets, subject to this policy.
- With your permission in any other case.
We do not sell personal information and do not share PHI with advertisers or social media platforms.
6. Cookies and analytics
We use cookies and similar tools to keep you signed in, remember preferences and understand how visitors use our public pages. We use Google Analytics to measure site traffic; you can opt out using Google's browser add-on at tools.google.com/dlpage/gaoptout. We do not place advertising or analytics trackers on pages where you enter health information. You can block cookies in your browser settings, but some features may stop working. We honor Global Privacy Control signals where required by law.
7. Emails and texts
We send messages about your care, orders and account, which you cannot opt out of while you have an active membership. Marketing emails include an unsubscribe link, and you can reply STOP to any text to stop marketing texts. We do not share your phone number with third parties for their own marketing.
8. How we protect information
We use administrative, technical and physical safeguards designed to protect your information, including encryption in transit, access controls limited to people who need it, and secure hosting. No system is completely secure, so please use a strong password and keep it private. If a breach affects your information, we will notify you as the law requires.
9. How long we keep information
We keep information for as long as your account is active and as needed to provide the Services, resolve disputes and meet legal duties. Medical records are kept for the period required by state and federal law, which can be several years after your last visit, even if you close your account.
10. Your rights and choices
- Access and copies: ask for a copy of your information, including your medical record.
- Correction: update your account in your profile or ask us to correct your records.
- Deletion: ask us to delete your account and information, subject to medical record retention laws.
- Marketing: opt out of marketing emails and texts at any time.
- HIPAA rights: for PHI, you also have the rights described in your provider's Notice of Privacy Practices, such as requesting restrictions or an accounting of disclosures.
To make a request, email support@thinkrmd.com. We will verify your identity before acting and respond within the time the law requires. We will not treat you differently for exercising your rights.
11. State privacy rights
Residents of some states — including California, Washington, Nevada, Connecticut, Colorado, Virginia and Texas — have additional rights, such as knowing what categories of information we collect and why, and limiting the use of sensitive information. Washington and Nevada residents have specific rights over "consumer health data," including the right to withdraw consent for its collection and sharing. We collect consumer health data only to provide the Services you request. To exercise any of these rights, or to appeal a decision we make about your request, email support@thinkrmd.com.
12. Children
The Services are only for adults aged 18 and over. We do not knowingly collect information from anyone under 18. If you believe a minor has given us information, contact us and we will delete it.
13. Links to other sites
Our site may link to other websites and services we do not control. Their privacy practices are governed by their own policies.
14. Changes to this policy
We may update this policy from time to time. We will change the "Last updated" date above and, for material changes, notify you by email or in your account before they take effect.
15. Contact us
Questions or requests about your privacy? Email support@thinkrmd.com or call (954) 944-9288, Monday–Friday, 8am–8pm ET.