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
Scope and How This Policy Works With HIPAA
Information We Collect
How We Use Your Information
Our Commitment on Health Information and Advertising
Cookies, Analytics, and Advertising
How We Share Your Information
Text Messaging
Reviews and Testimonials
Your Choices
Your State Privacy Rights
Children’s Privacy
How We Protect Your Information
Retention of Your Information
Third-Party Services, Links, and Social Media
Users Outside the United States
Changes to This Privacy Policy
Contact Us
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.
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:
Create and manage an account
Complete a health intake or questionnaire, or request treatment
Place an order or manage a subscription
Verify your identity
Contact us by email, chat, phone, or form
Join our ambassador or partner programs
Participate in surveys, research, or promotions
Upload photos or documents
Apply for a job with us
Depending on how you use the Services, this information may include:
Identifiers and contact information: name, email address, phone number, mailing and shipping address, and date of birth
Health information: medical history, conditions, symptoms, medications, allergies, lab results, photos, health goals, physical characteristics such as height and weight, and treatment and prescription information
Identity verification information: government-issued identification, such as a driver’s license, and photos submitted to confirm your identity and eligibility for care
Account information: login credentials and communication preferences
Payment information: billing address and card details. Card numbers are collected and processed directly by our payment processors; we do not store full card numbers.
Transaction information: products purchased, order history, subscriptions, and promo or referral codes used
Ambassador and partner information: if you join our ambassador or partner programs, your name, email address, phone number, social media handles, and business information. Payout details are collected and processed by our referral-tracking platform.
Communications: messages, chat transcripts, and feedback you send us
Demographic information: such as age and sex
Any other information you choose to provide
2.2 Information We Collect Automatically
When you use the Services, we and our service providers automatically collect certain information, including:
Device and usage information: IP address, browser type and language, operating system, device identifiers, pages viewed, links clicked, referring and exit pages, time spent on pages, search terms, dates and times of visits, and error logs
App information: device type, operating system and version, app version, and how you use the App
General location: city, state, or ZIP code inferred from your IP address. We use this to confirm service availability, calculate taxes, and tailor content. We do not collect precise geolocation (GPS) data.
We collect this information using cookies, pixels, tags, software development kits (SDKs), server logs, and similar technologies:
A cookie is a small text file stored on your device that helps us recognize your device, remember your preferences, understand how you use the Services, measure our marketing, and support security.
A pixel (also called a web beacon) is a small piece of code in a web page or email that records activity such as page visits, ad clicks, and email opens.
An SDK is code embedded in an App that allows information to be collected about how the App is used.
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:
Providers and pharmacies involved in your care, such as treatment status, prescription status, and order fulfillment updates
Service providers that support our business, such as payment processors, identity verification services, shipping carriers, and analytics providers
Referral, ambassador, and business partners, when you join through a partner link or code
Social media platforms, when you interact with our pages or content, such as your name, username, and the content of your comments or messages
We use your information to:
Provide the Services: create and manage your account, process orders and subscriptions, and coordinate shipping
Support your care: share your information with Providers and pharmacies so they can evaluate, treat, prescribe, and fulfill
Communicate with you: send account, order, shipping, and care-related messages, including messages sent on behalf of your Providers
Provide customer support: respond to your questions and requests. Our support chat may use AI-assisted tools, and you can ask to be connected with a member of our team at any time.
Process payments and verify identity: bill you, prevent fraud, and confirm eligibility
Market our Services: send promotional emails and messages, subject to your choices and Section 4
Run referral and partner programs: attribute orders to referral codes, communicate with ambassadors and partners, and calculate payouts
Improve the Services: understand how the Services are used, fix problems, and develop new features. When we share research results, we use only de-identified or aggregated information.
Protect you and others: maintain security, detect and prevent fraud and abuse, and enforce our Terms of Use
Comply with the law: meet legal, regulatory, and tax obligations, and establish, exercise, or defend legal claims
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.
Your health information is personal, and we treat it that way:
We do not sell your health information.
We do not use your health information to target advertising to you.
We do not share your health information with advertising platforms or social media companies. That includes your intake answers, conditions, symptoms, medications, treatments, and prescriptions.
We do not place advertising pixels or tracking technologies on pages where you enter health information. That includes our intake questionnaires and patient portal.
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:
Select “Your Privacy Choices” in the footer of our Websites to manage cookie preferences and opt out of the sale or sharing of your personal information for targeted advertising.
We recognize the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we treat it as a request to opt out of the sale or sharing of your personal information for targeted advertising, for that browser.
You can also opt out of interest-based advertising from participating companies through the Network Advertising Initiative and the Digital Advertising Alliance, and through Google’s Ad Settings.
To limit personalized ads in mobile apps, use the advertising settings on your iOS or Android device.
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.
We do not sell your personal information for money. We share information only as described below.
Providers and pharmacies: We share information with Providers and pharmacies so they can evaluate you, provide care, prescribe, and fulfill and ship your orders.
Service providers: We share information with companies that perform services for us under contracts that limit how they can use it. These include technology and hosting, telehealth platform, payment processing, identity verification, shipping and fulfillment, customer support, communications, analytics, security, and professional services such as legal and accounting. Service providers that handle PHI do so under HIPAA-compliant agreements.
Referral, ambassador, and business partners: If you join through a partner’s link or code, we share limited transaction information with the partner and our referral-tracking platform so we can credit the referral and pay the partner. This includes the code used, order date, and order value. We never share your health information, treatments, or prescriptions with partners.
Advertising partners: Limited online identifiers from our marketing Websites only, as described in Section 5, and never health information.
Legal and safety: We may disclose information when we believe in good faith it is reasonably necessary to:
comply with the law or legal process, such as a subpoena or court order
enforce our Terms of Use or other agreements
protect the rights, property, or safety of Soulera, our users, or others
prevent fraud or security threats
Business transfers: If Soulera is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction, including during its evaluation. Any successor will be bound by commitments at least as protective as those in this Privacy Policy, and by applicable law.
With your consent: We share information in other ways when you direct us to or give us permission.
De-identified information: We may share de-identified or aggregated information that cannot reasonably identify you.
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.
Message frequency varies. Message and data rates may apply.
Reply STOP to opt out at any time. You may receive one final message confirming your opt-out.
Reply HELP for help, or contact us at info@soulerawellness.com.
We do not share your mobile phone number or text messaging consent with third parties or affiliates for their marketing or promotional purposes.
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.
Marketing emails: Use the “unsubscribe” link in any marketing email, or contact us. You will still receive account, order, and care-related messages.
Text messages: Reply STOP, as described in Section 7.
Cookies and advertising: Select “Your Privacy Choices” in our Websites’ footer, or see Section 5.
Account information: You can review and update much of your account information in the patient portal, or contact us for help.
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:
Access: confirm whether we process your personal information and get a copy of it
Portability: receive the personal information you provided to us in a portable, readily usable format
Correct inaccurate personal information
Delete personal information we have collected from or about you
Third-party list: in some states, including Oregon, Delaware, and Minnesota, receive a list of the specific third parties we have disclosed your personal information to
Opt out of the sale or sharing of personal information for targeted advertising (see Section 5)
Opt out of profiling in furtherance of decisions with legal or similarly significant effects. We do not engage in this type of profiling.
Not be discriminated against for exercising your rights
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:
confirm whether we hold this information
give you access to it, including a list of the third parties we have shared it with
delete it
stop using it, by withdrawing your consent
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
Email info@soulerawellness.com with the subject line “Privacy Request.” Please send it from the email address associated with your account.
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.
We will verify your identity before responding, which may require additional information.
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:
we cannot verify your identity
the law requires us to keep the information
the information is part of a medical record maintained for your Providers
fulfilling the request would affect the rights of others
the request is excessive, repetitive, unfounded, or fraudulent
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:
Identifiers and contact information (name, email, phone, address, account name): service providers, Providers and pharmacies, referral partners (limited), legal and fraud prevention recipients
Commercial information (purchases and order history): service providers, Providers and pharmacies, referral partners (limited), legal and fraud prevention recipients
Financial information (payment card information, collected by our payment processors): payment processors, legal and fraud prevention recipients
Government identification (for identity verification): identity verification and service providers, Providers
Internet or network activity (IP address, browsing and app activity): service providers, advertising partners (marketing pages only), legal and fraud prevention recipients
General geolocation (city or state derived from IP address): service providers, legal and fraud prevention recipients
Demographic information (age, sex): service providers, Providers and pharmacies
Health and physical characteristics (health information and photos): Providers and pharmacies, service providers
Audio and electronic information (support chats and messages): service providers, Providers (when care-related)
Account credentials (login information): service providers
Professional information (job applications and ambassador or partner programs only): service providers, referral-tracking platform
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.
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.
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.
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.
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.
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.
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.
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