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Company Privacy Policy

Last Update Date: 12/3/2025

This Privacy Policy describes the information that CleopatraRX Development, LLC (“we” or “Company”) collects about you through our website(s), mobile application(s), and/or any other services we provide (collectively, the “Services”), how we use and share that information, and the privacy choices we offer. This policy applies to information we collect when you access or use our website(s) and/or mobile application(s) (collectively, the “Platform”), when you use our Services, or when you otherwise interact with us.

Changes to Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy on our Platform and revising the “Last Updated” date below. We encourage you to review the Privacy Policy whenever you use our Service to stay informed about our information practices and about ways you can protect your privacy.

Collection of Information

Information You Provide: We collect information you provide, such as when you email us, submit information through our Platform, or leave a comment or fill out a survey or questionnaire form on the Platform. We may collect, but are not limited to collecting the following information: your name, gender, age, email address, mailing address, phone number, payment and bank information provided. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Information We Collect from Your Use of the Services: We collect information about you when you use our Platform, including, but not limited to the following:

  • Account Information: When you register with us using the Platform to create an account, you will need to provide us with certain personally identifiable information to complete the registration, including information that can be used to contact or identify you and payment or other billing information.
  • Device Information: We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, browser user agent string to help in spam detection, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. We may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
  • Cookies: If you leave a comment, or fill out a form, on our Platform, you may opt-in to saving you name, email address, and website in cookies. These are for you convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me,” your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Aggregate and De-Identified Data: We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others for any purpose, in accordance with applicable laws and regulations.

Use of Information

We use the information that we collect for the following purposes:

  • For the purposes for which you provided the information.
  • To contact you when necessary or requested.
  • For the purposes for which you provided the information.
  • To personalize your experience with the Services by informing you of products, programs, events, services, and promotions of Company, our affiliates, our partners and/or third parties that we believe may be of interest to you.
  • To fulfill your purchase from us, including, to process your payments, communicate with you regarding your purchase or to provide you with customer service.
  • To schedule and facilitate telehealth visits.
  • To send mobile notifications.
  • To provide, maintain, administer, improve, or expand the Services, perform business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer.
  • To customize and tailor your experience of the Services.
  • To send emails and other communications that display content that we think will interest you and according to your preferences.
  • To send you news and information about our Services.
  • To track and analyze trends and usage in connection with our Services.
  • To better understand who uses the Services and how we can deliver a better user experience.
  • To combine information received from third parties with the information that we have from or about you and use the combined information for any of the purposes described in this Privacy Policy.
  • To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts.
  • To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities.
  • To enforce the legal terms that govern your use of the Services.
  • To protect our rights or property.
  • To administer and troubleshoot the Services.
  • For any other purpose disclosed to you in connection with our Services.

Sharing Information

We may share personal information about you as follows:

  • With your health care providers, to help them evaluate whether treatment is appropriate
  • With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf.
  • With our affiliates and partners so that they may use such information for the purposes described in this Privacy Policy.
  • With our affiliates, partners or other third parties to allow them to contact you regarding products, programs, services, and promotions that we and/or they believe may be of interest to you.
  • In connection with, or during the negotiation of, any merger, sale of Company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections).
  • If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; to enforce applicable user agreements or policies; to protect the security or integrity of our Services; and to protect us, our users or the public from harm or illegal activities.
  • With your consent.

We may also share aggregated, non-personally identifiable information with third parties.

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk.

Your Privacy Choices

  1. How You Can Access and Update Your Information: If you have an account on the Platform, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. You may update or correct information about yourself at any time or by emailing us at k.murray@cleopatrarx.com or 110 West 7th St., Ste. 900, Tulsa, OK 74119.
  2. Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, our Services may not function properly if you do so.
  3. Media. If you upload images to the Platform, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Platform can download and extract any location data from images on the Platform.
  4. Embedded Content from Other Websites: Articles on the Platform may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. We are not responsible for the privacy practices of third party websites. We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.
  5. No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties.
  6. How to Contact Us. Please contact use with any questions or concerns regarding this Privacy Policy at k.murray@cleopatrarx.com or 110 West 7th St., Ste. 900, Tulsa, OK 74119.

Confidentiality of Health Information and Our Role

When you set up an account with Company or leave comments on our Platform, you are creating a direct customer relationship with Company that enables you to access and/or utilize various functions of the Platform. As part of that relationship, you provide information to the Company, including but not limited to your name, email address, shipping address, and certain transactional information, which we do not consider to be “protected health information” or “medical information.”

However, in using certain components of the Platform, you may provide certain health or medical information that may be protected under applicable laws.

Company is not a healthcare provider and is not a “Covered Entity” under the Health Insurance Portability and Accountability Act of 1996 or its related regulations and amendments made from time to time (“HIPAA”). Company does not provide medical care, does not diagnose or treat conditions, and does not prescribe or dispense medications. All clinical decisions, including whether medication is appropriate, are made solely by an independent healthcare provider, such as pharmacies, prescribers, or other healthcare providers. One or more of these pharmacies, prescribers or other healthcare providers may or may not be a “Covered Entity” or “Business Associate” under HIPAA.

HIPAA does not necessarily apply to an entity or a person solely because there is health information involved and may not apply to all of your transactions or communications with Company or with any healthcare provider, pharmacy, or prescriber with whom you interact as a result of your use of the Platform. Nevertheless, any protected medical or health information that you provide that is subject to protections under applicable state or federal privacy laws (collectively, “PHI”) will be used and disclosed only in accordance with such laws, when applicable. However, information that does not constitute PHI under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. In some instances, even when HIPAA does not explicitly apply, we may voluntarily choose to comply with certain aspects of HIPAA to provide more protected and secure Services.

When one of your healthcare providers, pharmacies, or prescribers with whom you interact as a result of your use of the Platform is a “Covered Entity”, Company provides administrative, scheduling, support, and coordination services to such HIPAA Covered Entities. When doing so, Company may be acting as a HIPAA Business Associate to such healthcare providers, prescribers, and pharmacies. This means that Company receives, creates, and uses your PHI to assist those Covered Entities in providing you medical care.

When Company voluntarily chooses to comply with HIPAA or is acting as a Business Associate of Covered Entities, Company assumes no additional responsibilities beyond what is required by law. Notably, PHI does not include information that has been de-identified in accordance with applicable laws. You acknowledge and agree that your assessment responses may be collected, de-identified, and aggregated with those of other customers for the purposes of research, quality improvement, and program development. Below you will find a Notice of Privacy Practices that describes how we use and disclose PHI. By accessing or using any part of the Services, you acknowledge receipt of the Notice of Privacy Practices.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

We are dedicated to maintaining the privacy of any information that we collect that constitutes PHI under applicable law. PHI is information about you that may be used to identify you (such as your name, social security number, or address) and that relates to (a) your past, present, or future physical or mental health condition, (b) the provision of healthcare to you, or (c) your past, present, or future payment for the provision of healthcare. In conducting its business, Company may receive and create records containing your PHI.

This Notice is in effect from the “Last Updated” date below until the Company replaces it. Company reserves the right to change the terms of this Notice at any time, as long as the changes comply with applicable law. If we change the terms of this Notice, the new terms will apply to all PHI that we maintain, including PHI that was created or received before such changes were made to this Notice. If Company changes this Notice, we will post the new Notice on this Platform and will make the new Notice available upon request.

How We Use and Disclose Your PHI

We may use and disclose your PHI in the following ways:

  1. Treatment, Payment, and Healthcare Operations. We may use and disclose your PHI for the purposes of (a) treatment, (b) payment, and (c) healthcare operations. For example:

    • Treatment. We may disclose your PHI to a healthcare provider in connection with such provider’s provision of treatment to you.
    • Payment. We may use or disclose your PHI to a third party in connection with the processing of payment of claims and other charges related to your healthcare.
    • Healthcare Operations. We may use and disclose your PHI in connection with our healthcare operations, such as providing customer service and conducting quality review assessments. We may engage third parties to provide various services for the Company. If a third party must have access to your PHI to perform their services, we will require that third party to enter into an agreement that binds the third party to use and disclose your PHI only as outlined in this Notice.

  2. Authorization. We may use or disclose your PHI pursuant to your written authorization. You may revoke any such authorization at any time by providing written notice to us.

  3. As Required by Law. We may use and disclose your PHI to the extent required by law.

  4. Special Circumstances. We may use or disclose your PHI in certain special circumstances, such as:

    • As required by law, to public health or legal authorities charged with preventing or controlling disease, injury, abuse, or disability.
    • To researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your PHI.
    • To medical examiners, coroners, or funeral directors consistent with applicable law to enable them to carry out their duties upon your death.
    • To notify or assist in notifying a family member, a personal representative, or another person responsible for your care, location, and general condition.
    • Unless you object, to a family member, another relative, a close personal friend, or any other person that you identify, PHI relevant to that person’s involvement in your care or payment related to your care.
    • We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. If we contact you to provide marketing information for other products or services, you have the right to opt out of receiving such communications. Contact the Privacy Officer at
      k.murray@cleopatrarx.com
      or at 110 West 7th St., Ste. 900, Tulsa, OK 74119. If we receive compensation from another entity for the marketing, we must obtain your signed authorization.
    • To the FDA, PHI relative to adverse effects/events with respect to food, drugs, supplements, product or product defects, or post-marketing surveillance information to enable product recalls, repairs, or replacement.
    • To the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.
    • Under certain circumstances, if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
    • As permitted by applicable law, in response to an order from a court or administrative agency, or in response to a subpoena or discovery request.
    • For law enforcement purposes as required by law or in response to a valid subpoena.
    • To a health oversight agency for authorized activities such as audits, investigations, inspections, licensing and disciplinary actions relating to the healthcare system or government benefit programs.

Your Rights

Because Company is not your healthcare provider, your HIPAA rights (such as the right to access, amend, or restrict your PHI) are exercised through your healthcare provider. However, Company will assist any healthcare provider with which you have obtained a relationship through use of the Company website to respond to your request.

You have the following rights with regard to your PHI:

  1. Request restriction on uses and disclosures. You have the right to request a restriction or limitation on the PHI your healthcare provider may use or disclose about you for treatment, payment, or healthcare operations. Your healthcare provider is generally not required to agree to your request. If you request a restriction on a disclosure to a health plan for purposes of payment or health care operations (not for treatment), your healthcare provider must grant the request if the PHI pertains solely to an item or a service for which your healthcare provider has been paid in full. Company will comply with any restriction agreed to by a healthcare provider to the extent that such restriction is made known to Company.

  2. Obtain a copy of this notice of information practices. Although we have posted a copy on our website, you have a right to a hard copy upon request. To obtain a paper copy of this Notice, please contact the Privacy Officer at
    k.murray@cleopatrarx.com
    or at 110 West 7th St., Ste. 900, Tulsa, OK 74119.

  3. Confidential Communication. You have the right to receive confidential communications of your PHI. You may request that we or your healthcare provider communicate with you through alternate means, and we will accommodate your reasonable requests. You must submit any such request to Company in writing.

  4. Inspect and copy your PHI upon request. You have the right to inspect and obtain a copy of your PHI that your healthcare provider maintains in a designated record set, except for psychotherapy notes or information compiled in reasonable anticipation of or for use in civil, criminal, or administrative action or proceedings.

    Your healthcare provider may also deny access in the following situations:

    • PHI subject to the Clinical Laboratory Improvement Amendments of 1988 (CLIA), 42 U.S.C. § 263a, to the extent that giving you access would be prohibited by law.
    • Information that was obtained from someone other than a health care provider under a promise of confidentiality and the requested access would be reasonably likely to reveal the source of the information.
    • Information that is copyright protected, such as certain raw data obtained from testing.

    In other situations, your healthcare provider may deny you access, but if your healthcare provider does, your healthcare provider must provide you a review of your provider’s decision denying access. These reviewable grounds for denial include the following:

    • A licensed health care professional, such as your physician, has determined, in the exercise of professional judgment, that the access is reasonably likely to endanger the life or physical safety of yourself or another person.
    • PHI makes reference to another person (other than a health care provider), and a licensed health care provider has determined, in the exercise of professional judgment, that the access is reasonably likely to cause substantial harm to such other person.
    • The request is made by your personal representative, and a licensed health care professional has determined, in the exercise of professional judgment, that giving access to such personal representative is reasonably likely to cause substantial harm to you or another person.

  5. Request amendment or correction of your PHI. In most situations, you have a right to have your health care provider amend your PHI maintained in a designated record set. Your health care provider does not have to grant the request if the following conditions exist:

    • They did not create the record. In such cases, you must seek amendment or correction from the party creating the record. If the party amends or corrects the record, we will put the corrected record into our records to the extent we are provided with it.
    • The records are not available to you as discussed immediately above.
    • The record is accurate and complete.

  6. Obtain an accounting of nonroutine uses and disclosures. You can request an accounting of disclosures of your PHI for reasons other than for treatment, payment, and health care operations. Neither we nor your healthcare provider need to provide an accounting for the following disclosures:

    • To you for disclosures of PHI to you.
    • To persons involved in your care or for other notification purposes as provided in § 164.510 of the federal privacy regulations (uses and disclosures requiring an opportunity for the individual to agree or to object, including notification to family members, personal representatives, or other persons responsible for your care of your location, general condition, or death).
    • For national security or intelligence purposes under § 164.512(k)(2) of the federal privacy regulations (disclosures not requiring consent, authorization, or an opportunity to object).
    • To correctional institutions or law enforcement officials under § 164.512(k)(5) of the federal privacy regulations (disclosures not requiring consent, authorization, or an opportunity to object).

    We must provide the accounting within 60 days. The accounting must include the following information:

    • Date of each disclosure.
    • Name and address of the organization or person who received the PHI.
    • Brief description of the PHI disclosed.
    • Brief statement of the purpose of the disclosure that reasonably informs you of the basis for the disclosure or, in lieu of such statement, a copy of your written authorization or a copy of the written request for disclosure.

    The first accounting in any 12 month period is free. Thereafter, we reserve the right to charge a reasonable, cost-based fee.

  7. Complaints. You may complain to Company and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. To file a complaint with Company, you must submit a statement in writing to Company at
    k.murray@cleopatrarx.com
    or at 110 West 7th St., Ste. 900, Tulsa, OK 74119. Company will not retaliate against you for filing a complaint.

Our Responsibilities under HIPAA

In addition to providing you your rights, as detailed above, HIPAA requires us to take the following measures:

  • Maintain the privacy of your PHI, including implementing reasonable and appropriate physical, administrative, and technical safeguards to protect the information. Provide you this notice as to our legal duties and privacy practices with respect to individually identifiable health information that we collect and maintain about you.
  • Abide by the terms of this notice.
  • Train our personnel concerning privacy and confidentiality.
  • Implement a sanction policy to discipline those who breach privacy or confidentiality or our policies with regard thereto.
  • Notify you of and mitigate (lessen the harm of) any breach of privacy or confidentiality.

We will not use or disclose your PHI without your consent or authorization, except as described in this notice or otherwise required by law. These include most uses or disclosures of psychotherapy notes, marketing communications, and sales of PHI. Other uses and disclosures not described in this notice will be made only with your written authorization.