Privacy Policy

This Privacy Policy explains how Growth Ronin LLC, a Wyoming limited liability company doing business as STEMCIERGE (“STEMCIERGE,” “we,” “us,” or “our”) collects, uses, stores, discloses and protects personal information when you:

• Visit stemcierge.com
• Use our calculators, forms, questionnaires or other online tools
• Request information about stem cell therapy, regenerative medicine or healthcare providers
• Communicate with us by email, WhatsApp, telephone or other channels
• Submit medical or treatment-related information
• Request clinic matching, patient-navigation or concierge support
• Otherwise interact with STEMCIERGE

Some of the information you choose to provide may concern your health, medical history or treatment needs. We recognize that this information is sensitive and handle it accordingly.

STEMCIERGE is not a healthcare provider. We provide educational information, research, patient-navigation, clinic-matching and concierge support.

We collect personal and health information that you voluntarily provide when interacting with our website or services. The information we collect depends on how you interact with STEMCIERGE.

Contact Information

We may collect information such as:
• Name
• Email address
• Telephone or messaging contact information
• Country or region
• Preferred communication method
• Other contact information you choose to provide

Health and Treatment-Related Information

If you request personalized assistance or use services that require health-related information, we may collect information such as:

• Health conditions, symptoms or injuries
• Medical and treatment history
• Previous procedures or treatments
• Treatment interests and goals
• Medical records, reports or diagnostic information
• Medical imaging or other files you voluntarily provide
• Other health-related information relevant to your request

We only ask that you provide information reasonably relevant to the service you are requesting.Preferences and Service-Related Information

We may collect information concerning your preferences and circumstances relevant to the services you request, such as:

• Treatment interests
• Geographic or destination preferences
• Timing preferences
• Travel considerations
• Service preferences
• Other information you voluntarily provide to help us respond to your request

Information Submitted Through Digital Tools

When you use a STEMCIERGE calculator, form, questionnaire or similar tool, we may collect:
‍
• Information and answers you submit
• Contact information
• Tool results or estimates
• Interaction and completion information
• Consent records

Communications

We may retain records of communications between you and STEMCIERGE, including communications through:

• Email
• WhatsApp
• Telephone
• Website forms
• Other communication channels

These records may include information necessary to respond to your request or provide services you have requested.

Website and Technical Information

When you use our website, we and certain technology providers may automatically collect information such as:

• IP address
• Browser and device information
• Operating system
• Approximate geographic location derived from technical information
• Referring website or marketing source
• Pages viewed
• Website interactions
• Cookie and device identifiers
• Advertising identifiers where applicable
• Conversion or engagement events
• Website performance information

Certain information processed by STEMCIERGE may qualify as consumer health data, sensitive personal information, health data or special-category personal data under applicable law.

This may include:

• Health conditions, symptoms and treatment history
• Medical records, imaging and diagnostic information
• Treatment interests, goals and healthcare-seeking information
• Other health-related information voluntarily provided in connection with a request

Where applicable law requires consent or explicit consent before collecting, using or sharing certain health-related information, we will seek the appropriate consent.

You do not need to provide health information simply to browse the STEMCIERGE website.

Providing certain information may, however, be necessary if you request personalized services, provider introductions or assistance related to a healthcare inquiry.

We may collect personal information from the following categories of sources.

Directly From You

Most personal information we process is provided directly by you when you use our website, complete a form, use a digital tool or communicate with us.

Authorized Representatives

Information may be provided by a caregiver, family member or other representative acting with your authorization.

Healthcare Providers

Where you have requested or authorized communication with a healthcare provider, we may receive information from that provider in connection with your request.

Website and Technology Providers

Technical and online activity information may be collected automatically through our website and technologies used to operate, secure, measure and improve our services.

Other Legitimate Sources

Where permitted by law, we may receive information from referral sources, service providers or other parties involved in a request initiated or authorized by you.

We may use personal information for purposes including the following.

Providing Requested Services

We may use your information to:

• Respond to inquiries
• Provide requested information
• Operate our tools and digital services
• Provide personalized informational resources
• Provide clinic-matching, patient-navigation or concierge support
• Facilitate communications with selected healthcare providers
• Coordinate services requested by you

Communicating With You

We may use contact information to communicate regarding:

• Your inquiry
• Services you requested
• Provider communications
• Appointments or consultations
• Information relevant to your request
• Customer support

Operating and Improving STEMCIERGE

We may use information to:

• Operate and maintain our website
• Improve our services and user experience
• Understand how visitors use STEMCIERGE
• Measure website and service performance
• Develop or improve tools and features
• Perform internal analysis
• Maintain records

Security and Fraud Prevention

We may use information to:
‍
• Protect our website and systems
• Detect or prevent misuse
• Investigate suspicious activity
• Maintain information security
• Protect our users and business

Marketing and Educational Communications

Where permitted by applicable law, we may use contact information to provide:

• Educational content
• Relevant updates
• Newsletters
• Follow-up communications
• Information about STEMCIERGE services

You may opt out of marketing communications at any time.

Legal and Compliance Purposes

We may use information where reasonably necessary to:

• Comply with applicable law
• Respond to lawful requests
• Maintain legally required records
• Establish, exercise or defend legal claims
• Enforce our agreements

Where the GDPR, UK GDPR or another law requiring a legal basis applies, we may process personal information based on one or more of the following grounds.

Consent

We may process information where you have given consent for a particular purpose.

Explicit Consent

Where required for certain health-related or other sensitive information, we may rely on your explicit consent.

Providing Services Requested by You

We may process information where necessary to respond to your request, provide a requested service or take steps at your request.

Legitimate Interests

We may process information where reasonably necessary for legitimate business purposes such as operating, securing and improving STEMCIERGE, provided those interests are not overridden by your applicable privacy rights.

Legal Obligations

We may process information where necessary to comply with applicable legal requirements.

Where processing is based on consent, you may withdraw that consent for future processing, subject to applicable legal limitations.

Withdrawal does not affect processing lawfully carried out before withdrawal.

We may disclose personal information only where reasonably necessary for the purposes described in this Privacy Policy or otherwise permitted by law.

Selected Healthcare Providers

Where you request or authorize provider-related assistance, we may disclose relevant information to selected healthcare providers relevant to your request.

The information disclosed depends on the nature of your request and may include contact information and relevant health or treatment-related information.

We seek to limit disclosure to information reasonably necessary to facilitate the service requested.

Service Providers

We may disclose information to companies that provide services supporting our operations, such as:

• Website and infrastructure providers
• Cloud and data-storage providers
• Communication providers
• Customer-management systems
• Form and workflow providers
• Security providers
• Analytics providers
• Professional and administrative service providers

These parties may process personal information on our behalf or as otherwise permitted under applicable law.

Analytics and Advertising Partners

Certain technical, device and website interaction information may be disclosed to analytics and advertising providers as described in the section on Cookies, Analytics and Advertising Technologies.

Professional Advisers

Information may be disclosed where reasonably necessary to professional advisers such as attorneys, accountants, consultants or insurers.

Legal Requirements

We may disclose information where reasonably necessary to:

• Comply with applicable law or legal process
• Respond to lawful governmental requests
• Protect our rights or property
• Investigate fraud or security incidents
• Protect the safety of users or others

Business Transactions

If Growth Ronin LLC undergoes a merger, acquisition, financing, restructuring or sale of some or all of its business or assets, information may be transferred as part of that transaction, subject to applicable law.

Healthcare providers introduced, referenced or contacted through STEMCIERGE are independent third parties.

Healthcare providers are independently responsible for matters including:

• Their privacy practices
• Their patient records
• Medical assessments
• Medical recommendations
• Informed consent
• Treatment and clinical services

Once you provide information directly to a healthcare provider, that provider's own privacy policy and applicable laws generally govern its handling of that information.

STEMCIERGE does not control the privacy practices of independent healthcare providers.

STEMCIERGE may use cookies, pixels, tags and similar technologies to operate our website, understand website usage, measure performance and support marketing activities.

These technologies may collect information including:

• Cookie or device identifiers
• IP address
• Browser and device characteristics
• Referring source
• Pages visited
• Website interactions
• Advertising or campaign information
• Conversion events

We may use these technologies to:
• Measure website traffic
• Understand engagement
• Improve website performance
• Measure marketing effectiveness
• Understand how users discover STEMCIERGE
• Measure inquiries and conversions
• Support advertising or remarketing where permitted by law

Where required by law, non-essential technologies are used subject to applicable consent requirements.

You may be able to manage your preferences through our cookie or privacy controls and through your browser settings.

Health Information and Advertising

We do not intentionally disclose medical records, medical imaging, diagnostic documents or health-related responses submitted through patient forms or questionnaires to advertising platforms for targeted advertising purposes.

Advertising and analytics providers may receive general website interaction information as described above.In some jurisdictions, browsing particular health-related content may itself constitute or allow an inference about health interests.

Where such activity is treated as sensitive information or consumer health data under applicable law, we apply the consent and other requirements applicable to that processing.

STEMCIERGE does not sell personal information for money as a data-broker business.

Certain privacy laws define “sale,” “sharing,” or “targeted advertising” more broadly and may include some disclosures of online identifiers or browsing activity to advertising technology providers.

Where applicable law gives you the right to opt out of such activity, you may exercise that right through available privacy controls or by contacting us.

Where applicable, we may also recognize qualifying browser-based privacy preference signals.

We do not intentionally use medical records, diagnostic information or health-related intake responses for cross-context behavioral advertising.

This section provides additional information regarding consumer health data where laws such as state consumer health privacy laws apply.

Categories of Consumer Health Data

Depending on the services you use, consumer health data we may collect includes:

• Health conditions, symptoms and treatment history
• Medical records, diagnostic information and imaging
• Treatment interests and healthcare goals
• Information indicating or relating to an individual's interest in or request for healthcare-related services
• Other health information voluntarily provided in connection with a request

Purposes for Collecting Consumer Health Data

We may collect and use consumer health data to:

• Respond to healthcare-related inquiries
• Provide services requested by you
• Provide relevant informational tools or resources
• Facilitate communications or introductions requested by you
• Provide patient-navigation or related support
• Maintain appropriate records relating to your request

We will not knowingly collect or use additional categories of consumer health data for materially different purposes without providing any notice and obtaining any consent required by applicable law.

Sources of Consumer Health DataConsumer health data may be obtained from:

• You
• A representative authorized by you
• A healthcare provider where communication has been requested or authorized by you
• Information generated through services or digital tools you choose to use

Consumer Health Data We May Share

Depending on your request, categories of consumer health data shared may include:

• Relevant health or treatment information
• Medical records or diagnostic information you have chosen to provide
• Treatment interests or goals
• Information necessary to facilitate a service requested by you

Categories of Recipients

Consumer health data may be shared with categories of recipients including:

• Selected healthcare providers relevant to your request
• Service providers that support storage, communications, security or other operations necessary to provide our services
• Professional advisers or legally authorized recipients where necessary

We do not currently share consumer health data with a separate corporate affiliate for that affiliate's independent purposes.

Consumer Health Data and Advertising

We do not intentionally provide medical records, diagnostic files or health-related intake responses to advertising platforms for targeted advertising.

Where online activity itself constitutes consumer health data under applicable law, we process that activity subject to applicable requirements.

Sale of Consumer Health Data

We do not sell consumer medical records or health profiles as a commercial data product.

Certain laws may define a “sale” broadly enough to cover arrangements beyond the traditional exchange of data for money.

If a particular disclosure constitutes a sale of consumer health data under applicable law, we will obtain any separate authorization required before making that disclosure.

Consumer Health Data Rights

Where provided by applicable law, you may have the right to:

• Confirm whether we collect, use, share or sell consumer health data concerning you
• Access consumer health data concerning you
• Request deletion of consumer health data
• Withdraw consent to certain future collection or sharing
• Obtain information about certain recipients of consumer health data
• Appeal certain decisions regarding your privacy request

Requests may be submitted to info@stemcierge.com.

We may verify your identity before responding to a request where permitted or required by law.

If you provide contact information or request communication from STEMCIERGE, we may contact you using the communication method you provide or request.This may include:

• Email
• Telephone
• WhatsApp
• Other messaging services

Third-party communication services operate according to their own terms, privacy policies and security practices.

You should consider the privacy practices of any communication platform before using it to transmit sensitive information.

Where permitted by applicable law, STEMCIERGE may send educational, promotional or marketing communications.

You may unsubscribe from marketing email using the unsubscribe mechanism included in applicable communications or by contacting us.

You may also ask us to stop marketing communication through other channels.

Opting out of marketing does not prevent us from sending communications necessary to respond to an active request or provide a service you have requested.

STEMCIERGE serves users internationally and may work with service providers and healthcare providers located in different countries.

Personal information may therefore be processed or stored in jurisdictions outside your country of residence, countries in which relevant healthcare providers or service providers operate.

Where you request an introduction or assistance involving a provider in another country, relevant information may also be transferred to that jurisdiction.

Privacy laws in another jurisdiction may differ from those in your home country.

Where applicable law requires specific safeguards for international transfers, we will take appropriate measures required by law.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy or as otherwise required or permitted by law.

Factors we may consider when determining an appropriate retention period include:

• The nature of the information
• The sensitivity of the information
• The purpose for which it was collected
• Our ongoing relationship with you
• Legal, accounting or regulatory requirements
• The need to establish or defend legal claims

When information is no longer reasonably required, we may delete, anonymize or securely dispose of it.

We use reasonable administrative, organizational and technical measures designed to protect personal information against:

• Unauthorized access
• Unauthorized disclosure
• Loss
• Misuse
• Alteration
• Destruction

Access to sensitive information is intended to be limited to people and service providers who reasonably require access for an authorized purpose.

No internet transmission, cloud platform, storage system or communication method can be guaranteed to be completely secure.

Accordingly, we cannot guarantee absolute security.

If we become aware of a security incident involving personal information, we may investigate the incident and take measures we consider appropriate based on the circumstances.

Where applicable law requires notification to individuals, regulators or other parties, we will provide such notification in accordance with applicable requirements.

Depending on your location and the laws applicable to STEMCIERGE, you may have rights relating to your personal information.These may include the right to:

• Request access to personal information
• Request correction of inaccurate information
• Request deletion of information
• Request restriction of certain processing
• Object to certain processing
• Withdraw consent
• Receive certain information in portable form
• Opt out of targeted advertising
• Opt out of certain sales or sharing
• Limit certain uses of sensitive information
• Request information about certain recipients
• Appeal certain privacy decisions

Privacy rights vary by jurisdiction and may be subject to legal exceptions.

To submit a privacy request, contact:info@stemcierge.com

We may request information reasonably necessary to verify your identity and protect personal information from unauthorized disclosure.

We will not unlawfully discriminate against you for exercising an applicable privacy right.

Residents of California and certain other U.S. states may have additional rights where applicable state privacy laws apply to STEMCIERGE.

Depending on applicable law, these rights may include:

• The right to know what personal information is collected
• The right to access personal information
• The right to know the sources and purposes of collection
• The right to know categories of recipients
• The right to request deletion
• The right to correct inaccurate information
• The right to opt out of certain sales or sharing
• The right to opt out of targeted advertising
• The right to limit certain uses of sensitive personal information
• The right to non-discrimination for exercising applicable privacy rights

Where required by applicable law, we will provide mechanisms for exercising these rights and recognize qualifying opt-out preference signals.

Where the GDPR, UK GDPR or similar privacy legislation applies, individuals may have rights including:

• Access to personal data
• Correction of inaccurate data
• Erasure in qualifying circumstances
• Restriction of processing
• Objection to certain processing
• Data portability
• Withdrawal of consent
• Information regarding certain international transfers
• The right to lodge a complaint with an applicable supervisory authority

Health-related personal data may receive additional protection under these laws.

Where we rely on explicit consent for processing health-related information, you may withdraw that consent for future processing.

Where the Privacy Act 1988 (Cth), the Australian Privacy Principles (“APPs”) or other applicable Australian privacy laws apply, individuals in Australia may have additional rights regarding their personal information.

Depending on applicable law, these rights may include:

• Requesting access to personal information
• Requesting correction of inaccurate or outdated information
• Withdrawing consent where processing relies on consent
• Opting out of certain direct marketing communications
• Raising a privacy concern or complaint

Health information may receive additional protection under Australian privacy law.

Personal information may be processed, stored or disclosed outside Australia, including in the United States and countries where relevant healthcare providers or service providers operate.

To submit a privacy request or concern, contact: info@stemcierge.com

‍Where applicable, individuals may also have the right to raise a complaint with the Office of the Australian Information Commissioner (OAIC).

STEMCIERGE is not itself a hospital, physician practice, health plan or healthcare clearinghouse.

Information provided directly to STEMCIERGE should therefore not automatically be assumed to be protected health information governed by HIPAA in the same manner as information maintained by a healthcare provider subject to HIPAA.

Healthcare providers with whom you communicate may independently be subject to HIPAA or other healthcare privacy laws.

Where Growth Ronin LLC becomes subject to specific healthcare privacy requirements through an applicable legal or contractual relationship, we will comply with those requirements to the extent applicable.

Regardless of whether HIPAA applies, we recognize that health information is sensitive and seek to protect it appropriately.

STEMCIERGE's services are generally intended for adults.

We do not knowingly solicit personal or health information directly from children under 18 through our standard patient-navigation services.

Where a parent, legal guardian or other authorized representative contacts us regarding a minor, additional authorization may be required before certain information is processed or disclosed.

If you believe a minor has provided personal information without appropriate authorization, please contact us.

Our website may contain links to external websites or services.

These may include healthcare providers, publications, research organizations, travel services, social networks or other third parties.

STEMCIERGE does not control the privacy practices of independent third parties.Information you provide directly to those parties is governed by their own terms and privacy policies.

Our website may contain links to external websites or services.

These may include healthcare providers, publications, research organizations, travel services, social networks or other third parties.

STEMCIERGE does not control the privacy practices of independent third parties.Information you provide directly to those parties is governed by their own terms and privacy policies.

STEMCIERGE may use automated technologies to assist with operating digital tools, organizing information, providing estimates, personalizing website experiences or supporting internal workflows.

Automated tools used by STEMCIERGE are not intended to independently make medical diagnoses, determine medical candidacy or prescribe treatment.

Medical decisions must be made by appropriately qualified healthcare professionals.

We may update this Privacy Policy periodically to reflect changes in:

• Our services
• Our technology
• Our business practices
• Legal or regulatory requirements
• The way personal information is processed

When we update this Privacy Policy, we will revise the Last Updated date shown at the top.

Where required by applicable law, we may provide additional notice or obtain additional consent before materially changing the way certain information is collected, used or disclosed.