Privacy Policy

    Privacy Policy

    Soulera Wellness LLC

    Effective Date: October 15, 2026

    This Privacy Policy explains how Soulera Wellness LLC (“Soulera,” “we,” “our,” or “us”) collects, uses, shares, and protects your information. It applies when you visit soulerawellness.com, portal.soulerawellness.com, start.soulerawellness.com, or any other Soulera website that links to this Privacy Policy (the “Websites”), use any Soulera mobile application (the “Apps”), or otherwise interact with us. Together, these are the “Services.”

    This Privacy Policy is incorporated into our Terms of Use. Capitalized terms not defined here have the meanings given in the Terms of Use.

    If you use the Services on behalf of another person, you confirm that you are authorized to act for that person and that they acknowledge this Privacy Policy.

    State privacy rights: If you live in California or another state with a consumer privacy law, see Section 10 for additional rights that may apply to you.


    Please read this Privacy Policy carefully. If you do not agree with it, please do not use the Services.

    Contents

    1. Scope and How This Policy Works With HIPAA

    2. Information We Collect

    3. How We Use Your Information

    4. Our Commitment on Health Information and Advertising

    5. Cookies, Analytics, and Advertising

    6. How We Share Your Information

    7. Text Messaging

    8. Reviews and Testimonials

    9. Your Choices

    10. Your State Privacy Rights

    11. Children’s Privacy

    12. How We Protect Your Information

    13. Retention of Your Information

    14. Third-Party Services, Links, and Social Media

    15. Users Outside the United States

    16. Changes to This Privacy Policy

    17. Contact Us


    1. Scope and How This Policy Works With HIPAA

    Soulera operates a technology and wellness platform that connects you with independent, licensed healthcare providers (“Providers”) and licensed U.S. pharmacies. Soulera is not a healthcare provider and does not practice medicine.

    Soulera is not a “covered entity” under the Health Insurance Portability and Accountability Act (“HIPAA”). Providers and pharmacies may be covered entities. Health information that your Providers create or receive as part of your care is “protected health information” (“PHI”) and is governed by HIPAA and your Provider’s Notice of Privacy Practices, which your Provider makes available to you as part of your care.

    In some cases, Soulera may store or handle PHI on behalf of Providers, such as your medical record and communications with your care team. When we do, we act as a “business associate” and handle that information as HIPAA requires.

    Information that is not PHI. Information you give us to create and manage your account, such as your name, email address, phone number, and shipping address, is not PHI. Neither is information collected through our Websites and Apps. This Privacy Policy governs that information and applicable state law.



    2. Information We Collect

    We collect only the information we need to provide and improve the Services. If you choose not to provide certain information, or ask us to delete it, you may not be able to use some or all of the Services.

    2.1 Information You Provide to Us

    You provide information when you:

    Depending on how you use the Services, this information may include:

    2.2 Information We Collect Automatically

    When you use the Services, we and our service providers automatically collect certain information, including:

    We collect this information using cookies, pixels, tags, software development kits (SDKs), server logs, and similar technologies:

    See Section 5 for how we use these technologies and how to manage them.

    2.3 Information From Other Sources

    We may receive information about you from:



    3. How We Use Your Information

    We use your information to:

    De-identified information. We may de-identify or aggregate information so it can no longer reasonably be linked to you. We maintain de-identified information in de-identified form and do not attempt to re-identify it, except as permitted by law to test our de-identification methods.



    4. Our Commitment on Health Information and Advertising

    Your health information is personal, and we treat it that way:



    5. Cookies, Analytics, and Advertising

    Analytics. We use analytics services, such as Google Analytics, to understand how visitors use our Websites and to improve them. These services may use cookies and similar technologies to collect information about your visits. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

    Email analytics. Our emails may contain pixels that tell us whether a message was opened or a link was clicked. We use this to measure the effectiveness of our communications. Most email apps let you block images by default, which also blocks these pixels.

    Advertising. On our marketing Websites (not intake or portal pages), we may work with advertising partners such as Google and Meta. They use cookies and similar technologies to show Soulera ads on other websites and apps, and to measure how those ads perform. These ads may be based on your visits to our marketing pages. They are not based on your health information.

    Your advertising choices:

    Opt-outs are specific to each browser and device, so you may need to set them on each one. If you opt out, you will still see ads, but they will not be tailored to your activity.

    Managing cookies. Most browsers let you block or delete cookies through their settings. Some cookies are essential for the Websites to work and cannot be disabled. Blocking some cookies may affect how the Services work, and deleting cookies may reset your preferences, including advertising opt-outs.

    Do Not Track. Apart from the Global Privacy Control signal described above, we do not currently respond to browser “Do Not Track” signals, because there is no common industry standard for them.



    6. How We Share Your Information

    We do not sell your personal information for money. We share information only as described below.



    7. Text Messaging

    If you provide your mobile number, you may receive text messages about your account, orders, shipments, and care. If you separately opt in, you may also receive promotional texts. Consent to promotional texts is not a condition of purchase. By providing a mobile number, you confirm that you are the subscriber or customary user of that number.



    8. Reviews and Testimonials

    If you submit a review, testimonial, or other content to us, we may display it on our Websites, social media, or in our marketing. We will only use content that identifies you, such as your name, photo, or likeness, with your express permission. When displayed, testimonials typically show only your first name, last initial, and general location.

    You can ask us to update or remove your testimonial at any time by contacting us. Copies that have already been shared publicly may remain in cached or archived pages, or may have been copied by others.



    9. Your Choices



    10. Your State Privacy Rights

    10.1 Your Rights

    Residents of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states with consumer privacy laws may have some or all of the following rights, subject to verification and exceptions:

    10.2 Sensitive Personal Information

    Health information is “sensitive” under many state laws. We use and disclose sensitive personal information only to provide the Services you request and for other purposes permitted by law, or with your consent. We do not sell sensitive personal information, do not use it for targeted advertising, and do not use it to infer characteristics about you. This applies in every state, including Maryland and Texas.

    10.3 Health Data Rights in Certain States

    Some states, including Washington, Nevada, and Connecticut, give you added rights over health-related information that is not covered by HIPAA. We collect and share this information only with your consent or as needed to provide the Services you request, and we never sell it or use it for advertising. You may ask us to:

    Use the process in Section 10.4. We do not use geofencing around healthcare facilities to track or message consumers.

    10.4 How to Exercise Your Rights

    1. Email info@soulerawellness.com with the subject line “Privacy Request.” Please send it from the email address associated with your account.

    2. Include your full name, mailing address, state of residence, and the right you want to exercise, with enough detail for us to understand and respond to your request.

    3. We will verify your identity before responding, which may require additional information.

    4. If you would like a copy of your medical record, please say so in your request. Medical record requests are handled together with your Provider.

    To opt out of the sale or sharing of personal information for targeted advertising, select “Your Privacy Choices” in our Websites’ footer or use the Global Privacy Control signal.

    Exceptions. We may decline all or part of a request if:

    Where the law allows, we may charge a reasonable fee for excessive or repetitive requests. If we decline a request, we will tell you why. PHI is governed by HIPAA and your Provider’s Notice of Privacy Practices.

    Authorized agents. You may use an authorized agent to make a request on your behalf, where your state allows it. We will verify both your identity and the agent’s, and require written proof of the agent’s authority. A valid power of attorney is also accepted.

    Appeals. If we decline your request, you may appeal by replying to our decision with the subject line “Privacy Request Appeal.” We will respond within the time required by law. If your appeal is denied, we will tell you how to contact your state Attorney General or regulator.

    10.5 California Residents

    This section applies to California residents under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). If it conflicts with the rest of this Privacy Policy, this section controls for California residents.

    Categories of personal information we collected in the past 12 months, and the categories of recipients we disclosed them to for business purposes:

    Sources and purposes: Sections 2 and 3 describe our sources and business purposes.

    Sale or sharing: We do not sell personal information for money. Making online identifiers and internet activity from our marketing pages available to advertising partners may be considered “selling” or “sharing” under California law. You can opt out as described in Section 5. We do not knowingly sell or share the personal information of anyone under 16.

    Sensitive personal information: We use sensitive personal information only for purposes permitted under the CCPA, such as providing the Services you request. Because we do not use it for other purposes, the right to limit its use does not apply. You may still contact us with questions.

    Retention: See Section 13.

    Shine the Light: We do not share personal information with third parties for their own direct marketing purposes.

    10.6 Nevada Residents

    We do not sell “covered information” as defined under Nevada law. You may still submit an opt-out request for any future sale to info@soulerawellness.com.



    11. Children’s Privacy

    The Services are intended only for adults 18 and older, or any older age required by the law of your state. We do not knowingly collect, sell, or share personal information from anyone under 18. If we learn we have collected information from someone under 18, we will delete it unless we are required by law to keep it. If you believe a minor has provided us with information, please contact us.



    12. How We Protect Your Information

    We use administrative, technical, and physical safeguards designed to protect your information. These include encryption in transit, access controls, and HIPAA-compliant systems and agreements for health information.

    No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please keep your password confidential and contact us right away if you believe your account has been compromised. If a security incident affects your information, we will notify you as required by law.



    13. Retention of Your Information

    We keep personal information only as long as necessary for the purposes described in this Privacy Policy. This includes providing the Services, maintaining records required by law, resolving disputes, and enforcing our agreements.

    How long we keep information depends on the type of information, why we collected it, and our legal obligations. When information is deleted, it is removed from active systems, but copies may remain in secure backups for a limited time until they are overwritten. Providers and pharmacies keep medical and prescription records for the periods required by applicable state and federal law. Third parties we work with keep information under their own retention policies.



    14. Third-Party Services, Links, and Social Media

    The Services may link to or integrate with third-party websites, apps, and services that we do not control, including payment processors. Their privacy practices are governed by their own policies, not this Privacy Policy, and we encourage you to review them.

    We are active on social media platforms such as Instagram, Facebook, and TikTok. Anything you post publicly on social media, including comments on our pages, is public and governed by that platform’s policies and terms. Please do not share health information in public posts or comments.



    15. Users Outside the United States

    The Services are intended for individuals located in the United States. Information is stored and processed in the United States, and this Privacy Policy is governed by U.S. law.



    16. Changes to This Privacy Policy

    We may update this Privacy Policy from time to time to reflect changes in the law, our practices, or the Services. The effective date at the top shows when it was last updated. If we make material changes, we will notify you by email, through the Services, or as otherwise required by law. If required by law, we will ask for your consent before applying a material change to information we have already collected.



    17. Contact Us

    If you have questions about this Privacy Policy or our privacy practices, contact us at:

    Soulera Wellness LLC
    2650 Cedar Springs Road, Unit 7726
    Dallas, TX 75201
    United States
    info@soulerawellness.com