Privacy Policy

1 Scope

This Policy applies to personal information processed through websites, inquiry forms, consultations, newsletters, communications, and other services operated by Wellness Beyond Borders that link to this Policy. A separate notice or agreement may apply to a specific program, transaction, employer or organizational relationship, or clinical workflow.

This Policy does not govern the independent privacy practices of hospitals, clinics, physicians, laboratories, travel providers, payment processors, or other organizations that WBB does not control. Those organizations may provide their own privacy notices and may be subject to different laws.

2 Who We Are and Our Role

Wellness Beyond Borders (WBB, we, us, or our) coordinates access to independent medical providers and related travel and hospitality services. WBB does not itself diagnose, treat, or practice medicine. When WBB decides why and how personal information is processed for its own services, WBB is the controller or business responsible for that information under applicable privacy law.

Healthcare providers are independent organizations. If you authorize WBB to share information with a provider, that provider may process the information for its own clinical, administrative, legal, and regulatory purposes under its own privacy notice, medical-record rules, and applicable law.

3 Personal Information We Collect

Identity and contact information

Name, email address, telephone number, city, state or province, country, preferred language, and similar contact details.

Inquiry and health-interest information

The health areas you wish to explore, your reasons for contacting WBB, prior assessment experience, questions, priorities, and information you voluntarily provide during an introductory conversation.

Experience and travel preferences

Preferred timing, destination interests, whether you may travel alone or with others, accommodation or coordination preferences, and group or organizational interest.

Communications

Emails, telephone notes, messages, consultation records, feedback, consent records, and customer-support correspondence.

Transaction information

If you purchase services, billing details, payment status, invoices, refunds, and transaction identifiers. Payment card information may be processed directly by a payment processor rather than WBB.

Device and usage information

IP address, browser and device type, operating system, referring URL, pages viewed, timestamps, approximate location derived from IP address, and website interactions.

Cookie and preference information

Cookie identifiers, consent choices, language and display preferences, analytics events, and marketing-subscription preferences.

Information about another person

Information you provide when you inquire for a spouse, family member, friend, client, or organization, if you are authorized to do so.

4 Sensitive Health Information

Information about health interests, symptoms, diagnoses, treatments, genetics, fertility, medications, medical records, and even visits to certain health-related pages may be sensitive information or consumer health data under applicable law. We use health-related inquiry information only for the purposes described in this Policy and apply heightened access, use, and disclosure restrictions.

Do not send medical records, diagnoses, test results, or other detailed clinical information through the general website inquiry form. If records are needed later, WBB or an independent provider will explain the appropriate authorized process and any additional privacy terms that apply.

5 How We Collect Information

We collect information directly from you when you browse the website, submit an inquiry, speak with us, subscribe to communications, or purchase services. We may receive information from a person authorized to act for you, from an organization sponsoring or arranging an experience, from independent providers or travel partners when needed to coordinate an authorized service, and from vendors that support website analytics, communications, security, and payment processing.

6 How We Use Personal Information

• Respond to inquiries and arrange introductory consultations.

• Understand your goals, priorities, timing, and preferred experience.

• Coordinate, at your direction, with independent healthcare, diagnostic, travel, hospitality, translation, and logistics providers.

• Administer agreements, payments, scheduling, travel support, customer service, and related business operations.

• Send service communications and, with any consent required by law, newsletters or marketing communications.

• Operate, secure, troubleshoot, analyze, and improve our website and services.

• Prevent fraud, misuse, security incidents, and unlawful activity; establish or defend legal claims; and comply with legal obligations.

• Create aggregated or deidentified information that cannot reasonably be linked to an individual, subject to applicable law.

7 Legal Bases for Processing

Where the law requires a legal basis, WBB relies on one or more of the following: your request for pre-contractual steps or performance of a contract; your consent; WBB's legitimate interests in operating, securing, and improving its services where those interests are not overridden by your rights; compliance with legal obligations; protection of vital interests in limited circumstances; and, for health or other special-category data, explicit consent or another condition permitted by law.

You may withdraw consent at any time where processing relies on consent. Withdrawal does not affect processing already carried out lawfully and may limit our ability to provide a requested service.

8 How We Disclose Personal Information

Independent providers you authorize

To respond to a request, assess availability, arrange consultations or diagnostics, coordinate care or logistics, and provide the services you request.

Service providers and processors

Hosting, cybersecurity, CRM, communications, customer support, analytics, document management, payments, translation, and other operational support under contractual restrictions.

Travel and hospitality providers

Only as reasonably necessary to arrange authorized transportation, accommodation, concierge, or related logistics.

Professional advisers and insurers

Legal, accounting, audit, insurance, risk-management, and similar professional services.

Authorities and legal recipients

When required by law or valid legal process, or reasonably necessary to protect rights, safety, security, or prevent fraud or abuse.

Corporate transaction recipients

In connection with a proposed or completed merger, financing, reorganization, sale, or transfer, subject to appropriate confidentiality and legal safeguards.

At your direction

To another person or organization you ask or authorize us to involve.

9 Independent Providers

Independent providers determine their own clinical and recordkeeping practices. After a provider receives information with your authorization, it may act as a separate controller, business, covered entity, or other regulated organization. WBB does not control the provider's clinical records, medical decisions, or independent privacy practices.

10 Sale Sharing and Targeted Advertising

WBB does not sell medical records or information submitted in a consultation inquiry for money. WBB does not use the contents of consultation inquiries or medical records for third-party targeted advertising.

Some privacy laws define sale, sharing, or targeted advertising broadly enough to include certain cookie or analytics disclosures even when no money changes hands. If WBB uses technology that is legally treated in this way, WBB will provide any required notice and opt-out method and will honor recognized universal opt-out signals where required. WBB will not use sensitive health information for advertising without the consent required by law.

11 Cookies and Similar Technologies

WBB and its authorized vendors may use cookies, pixels, local storage, logs, and similar technologies to operate the website, remember preferences, maintain security, measure performance, and understand how the site is used. Non-essential analytics or advertising technologies will be used only as permitted by law and your choices. You can manage available choices through the website's cookie controls or your browser settings. Blocking certain technologies may affect site functionality.

12 International Processing and Transfers

WBB is based in the United States and coordinates services that may involve organizations in other countries, including Türkiye. Personal information may therefore be processed in countries with privacy laws that differ from those where you live. When required, WBB uses appropriate contractual or other safeguards for international transfers. Independent providers may be subject to the laws of the country in which they operate.

13 Data Retention

WBB retains personal information only for as long as reasonably necessary for the purposes described in this Policy, including to manage inquiries and active coordination, provide customer support, maintain security and consent records, satisfy accounting or legal duties, resolve disputes, and establish or defend claims. Retention periods vary by information type, sensitivity, relationship status, and legal requirement. WBB seeks shorter retention for detailed health information and deletes or deidentifies information when it is no longer reasonably needed, unless law requires or permits longer retention.

14 Security

WBB uses reasonable administrative, technical, and physical safeguards designed to protect personal information based on its nature and sensitivity. No method of transmission or storage is completely secure, and WBB cannot guarantee absolute security. If you believe information has been compromised, contact WBB promptly through the website.

15 Your Choices and Privacy Rights

Depending on where you live and subject to legal exceptions, you may have the right to know or access personal information, correct inaccuracies, request deletion, obtain a portable copy, restrict or object to processing, withdraw consent, opt out of sale, sharing, targeted advertising, or certain profiling, limit certain uses of sensitive information, and appeal a denied request. You will not be discriminated against for exercising a privacy right.

You may unsubscribe from marketing emails using the link in the message. Service communications about an active inquiry or purchased service are not marketing. To make a privacy request, contact WBB through the website and identify the right you wish to exercise. WBB may verify your identity and authority before acting. An authorized agent may submit a request where applicable law permits.

Residents of the European Economic Area or United Kingdom may also complain to their local data-protection authority. Residents of U.S. states may have the right to contact their state attorney general or another designated regulator.

16 Consumer Health Data Notice

Where a U.S. state consumer-health law applies, this section supplements the rest of the Policy. WBB may collect health interests, assessment priorities, family-history concerns, fertility or genetic interests, diagnostic preferences, and information that permits an inference about a consumer's health. Sources include the consumer, an authorized representative, website interactions, and organizations involved at the consumer's direction.

WBB collects and uses consumer health data to respond to requests, determine whether the WBB experience may fit the consumer's goals, coordinate authorized services, communicate, maintain security, and comply with law. WBB may disclose the data to independent providers and operational vendors only for these purposes, as described above, or as the consumer directs. WBB does not sell consumer health data. Where required, WBB will obtain separate consent before collecting or sharing consumer health data and separate authorization before any sale.

Applicable rights may include confirming collection or sharing, accessing a list of third parties, withdrawing consent, and deleting consumer health data. Contact WBB through the website to exercise these rights or appeal a decision.

17 HIPAA and Other Health Privacy Laws

The Health Insurance Portability and Accountability Act (HIPAA) applies to covered entities and their business associates; it does not automatically apply to every organization that handles health-related information. WBB's general consumer coordination activities are not represented as HIPAA-covered merely because a person expresses a health interest. If WBB enters a workflow in which it is legally a business associate, a separate agreement and applicable HIPAA requirements may govern that information. Health-related information outside HIPAA may still be protected by the Federal Trade Commission Act, state consumer-health laws, data-breach laws, the GDPR or UK GDPR, and other applicable law.

18 Children

The website and WBB's services are intended for adults. WBB does not knowingly invite children to submit inquiries independently. A parent, legal guardian, or other authorized adult may inquire for a minor when legally permitted and represents that they have authority to do so. If you believe a child provided information without required authorization, contact WBB through the website.

19 Third Party Links and Services

The website may link to independent providers, travel services, payment services, social platforms, or other third parties. Those organizations may collect information under their own terms and privacy notices. WBB is not responsible for the privacy or security practices of organizations it does not control.

20 Changes to This Policy

WBB may update this Policy to reflect changes in services, technology, law, or data practices. WBB will post the revised Policy and update the date above. If a change materially affects the handling of sensitive information or your rights, WBB will provide additional notice or obtain consent where required. A privacy policy is a notice; where the law requires consent, WBB will seek that consent separately rather than treating continued website use alone as consent.

21 Contact Us

For privacy questions, complaints, or requests, contact Wellness Beyond Borders through the Contact WBB or private consultation channel on the website and mark the request for the attention of Privacy. Please do not include medical records or detailed clinical information in a general privacy request.