Last updated: August 20, 2026
Privacy Statement-California
This PRIVACY NOTICE IS APPLICABLE TO CALIFORNIA RESIDENTS (“consumers” or “you”) ONLY and supplements the information in AspenMD LLC’s AspenMD general Privacy Statement. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act ("CPRA"), and other California privacy laws. Any terms defined in the CCPA or CRPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”).
We have collected the following categories of Personal Information from California consumers since August 20, 2026 on AspenMD LLC’s AspenMD Platform:
Category
A. Identifiers.
Examples: Name, postal address, shipping address, email address, telephone number, date of birth, account name and login credentials, IP address, and other unique online identifiers.
Collected: Yes
Category
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, address, telephone number, driver’s license or state identification card number, medical information, bank account number, credit card number, debit card number, or other financial information. AspenMD does not bill insurance and does not collect health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes
Category
C. Characteristics of protected classifications under California or federal law.
Examples: Age, sex, gender, and pregnancy or related medical conditions, where clinically relevant to the treatment you request.
Collected: Yes
Category
D. Commercial information.
Examples: Records of products and services purchased or considered, order and subscription history, membership status, and payment information processed by our payment providers.
Collected: Yes
Category
E. Biometric information.
Examples: Physiological or biological characteristics used to establish identity, such as fingerprints, voiceprints, or facial geometry. Clinical information, including laboratory results, is described in category B.
Collected: No
Category
F. Internet or other similar network activity.
Examples: Browser and device type, IP address, cookie and pixel identifiers, pages viewed, referring URLs, quiz and form interactions, email and text message engagement, and account activity logs.
Collected: Yes
Category
G. Geolocation data.
Examples: Precise geolocation, such as latitude and longitude reported by a mobile device. Approximate location may be inferred from an IP address, which is described in category F.
Collected: No
Category
H. Sensory data.
Examples: Audio and video from telehealth consultations with your provider, and photographs you submit in connection with your care.
Collected: Yes
Category
I. Professional or employment-related information.
Examples: Current or past job history and performance evaluations.
Collected: No
Category
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No
Category
K. Inferences drawn from other personal information.
Examples: Preferences and characteristics inferred from the information above, such as communication and delivery preferences, product interests, and treatment eligibility indicators.
Collected: Yes
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from the intake questionnaire, account registration, checkout, and messages you send us.
- Indirectly from your use of our Sites. For example, from cookies and similar technologies, and from your activity on our website.
- From the licensed providers, pharmacies, and laboratories that deliver your care, and from service providers that support our platform, such as payment and shipping providers.
Personal Information does NOT include:
- Information that is lawfully made available from federal, state, or local government records (“Publicly Available Information”).
- De-identified or aggregate consumer information (as such terms are defined in the CCPA).
- Information excluded from the CCPA's scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Sensitive personal information means Information that reveals:
- Your social security, driver’s license, or passport number.
- Your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to the account.
- Your precise geolocation.
- Your racial or ethnic origin, religious or philosophical beliefs, or union membership.
- Contents of your mail, email, and text messages unless AspenMD is the intended recipient of your communication.
- Your genetic data.
Unless the information is publicly available, sensitive personal information also includes:
- Processing of biometric information for the purpose of uniquely identifying you.
- Personal information collected and analyzed concerning your health.
- Personal information collected and analyzed concerning your sex life or sexual orientation.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products, or services.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis, and product development.
- As reasonably necessary and proportionate to protect the rights, property or safety of us, our patients, or others.
- To respond to regulatory and/or law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To third party service providers who perform marketing or other services on our behalf
- To our affiliates and subsidiaries.
- As otherwise required or permitted by law.
We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your Personal Information to a third party for a business purpose.
In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business purpose: None.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates
- Service Providers and Vendors
- Third parties to whom you authorize us to disclose your personal information in connection with products or services we provide to you.
- Our independent contractor insurance agents.
- To other third parties as required or permitted by law.
Selling Personal Information
We do not sell your personal Information to anyone.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information collected on or after August 20, 2026. Once we receive and verify your request, we will disclose to you any of the following in accordance with your request:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we have collected about you (also called a data portability request) – but only if specifically requested by you.
- If we have sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- Sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Correction Requests
You have the right to request that we correct personal information about you. After we receive and verify your request, we will evaluate the requested correction against information we receive from other sources. We will disclose to you the actions taken pursuant to your request.
Opting Out of Use and Disclosure of Sensitive Personal Information
You have the right to request that we limit the use and disclosure of your Sensitive Personal Information, subject to certain exceptions. We use your Sensitive Personal Information to perform the services reasonably expected. We may also use your Sensitive Personal Information to ensure the security and integrity of your Personal Information, conduct non-personalized advertising, perform services on behalf of our business, and undertake activities to improve or enhance our services.
Deletion Request Rights
You have the right to request that we delete (and direct our Service Providers to delete) your Personal Information from our records. Subject to the exceptions set forth below, we will comply with your deletion request and will direct our Service Providers to delete your Personal Information.
Deletion Request Exceptions
We (or our Service Providers) do not have to comply with your deletion request with regard to your Personal Information that we (or our Service Provider) maintain for any of the following reasons:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Visiting aspenmd.com
Emailing support@aspenmd.com
Only you or a person registered with the California Secretary of State for which you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify your identity or your authority to make a request on behalf of a California resident.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. Personal Information provided will only be used by us to verify the requestor's identity and/or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will provide you with a cost estimate and rationale before completing your request. We also reserve the right to deny excessive, repetitive, or manifestly unfounded requests.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your options and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Website: www.aspenmd.com
Email: support@aspenmd.com
Postal Address:
AspenMD LLC
8 The Green, Suite A, Dover, DE 19901
AspenMD is a patient management platform that works with independent physicians and practitioners who provide services utilizing the AspenMD Platform. AspenMD does not directly provide medical, or pharmacy services and payment does not guarantee the writing or dispensing of a prescription. Medical Services are provided via independent licensed providers. The information provided on this website is for informational purposes and not a substitute for professional medical advice, diagnosis, or treatment. If you have questions or concerns about your health, please talk to your doctor. This site is an advertisement for services and not any specific medication.