Privacy

Privacy Policy

Effective Date: May 5, 2026

This Privacy Notice describes how Lttl Health, Inc. ("Lttl," "we," "us") uses, discloses, and protects the personal information we collect through the Lttl website, lttl.com, and related services.

Key Privacy Points

• Lttl does not provide medical advice. We help individuals connect with independent third-party healthcare providers ("Healthcare Providers") and may provide non-medical information and support services.
• We collect initial qualifying information that is shared with relevant Healthcare Providers for assessment. If appropriate, the Healthcare Provider will invite you to schedule an initial appointment through their patient portal (the "Patient Portal"), which is not operated by Lttl.
• Diagnosis, consultation, and treatment are provided exclusively by the Healthcare Provider. Lttl does not diagnose or treat any disease or medical condition.
• Healthcare Providers and any Patient Portal are subject to their own privacy policies and practices. Lttl is not responsible for the management of personal or health information collected by or through a Healthcare Provider or a Patient Portal.
• Your relationship with pharmacies and third-party suppliers is subject to their own privacy practices, regardless of whether the Lttl logo appears in those interactions.

1. Information We Collect

Information you provide

• Name and contact information
• Basic health or medical information you choose to share
• Any other information you provide when interacting with our services

Information collected automatically

We and third parties may collect information from your computer or device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality, and other computer code. This may include unique browser identifiers, IP address, browser and operating system information, device identifiers, internet connection information, and details about your interactions with the Lttl website.

Cookies

We may use the following types of cookies:

• Necessary cookies — essential for the operation of our website.
• Performance cookies — help us understand how visitors use our site so we can improve it.
• Functionality cookies — remember your choices to provide a more personalized experience.
• Targeting/advertising cookies — used to deliver more relevant advertisements and measure their effectiveness.

Most web browsers allow you to control cookies through their settings. Disabling cookies may affect functionality of our site.

2. Use of Information

• Manage and improve Lttl services and provide services to you and to Healthcare Providers
• Customize content on our website and elsewhere
• Send confirmations, updates, alerts, and support and administrative messages
• Conduct business operations such as marketing, auditing, security, fraud prevention, invoicing, analytics, and research
• Protect against, identify, investigate, and respond to misuse of our website or other unlawful behavior
• Address legal requirements and establish, exercise, or defend our legal rights
• Create aggregated or de-identified information for any lawful purpos‍

3. Disclosure of Information

• To Healthcare Providers, Patient Portals, and third-party services that support your care.
• To vendors and service providers that operate our website, host data, analyze usage, or provide customer service, marketing, security, or fraud prevention.
• To current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Lttl.
• As required by law, including in response to subpoenas, court orders, or other valid government requests.
• When we believe disclosure is appropriate to investigate or prevent illegal activity, suspected fraud, or to protect the rights, property, or safety of Lttl, our employees, our customers, or others.
• In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business.

4. Your Rights and Choices

Marketing communications

You can unsubscribe from Lttl marketing emails at any time by clicking the unsubscribe link in any marketing email or by contacting us at info@lttl.com. Even if you opt out of marketing emails, you may still receive non-marketing messages related to your account or services you have requested.

SMS communications

When you provide your mobile number, you may receive recurring SMS messages from Lttl, including service updates and, with your consent, marketing messages. You can opt out of marketing SMS messages at any time by replying STOP. Message and data rates may apply.

Cookies and tracking

You can control cookies and similar technologies through your browser settings. We do not respond to browser-based do-not-track signals.

5. Protection of Information

Lttl maintains physical, technical, and administrative safeguards designed to protect personal information. However, no system is completely secure and we cannot guarantee the absolute security of your information.

6. Children

Our services are intended only for adults 18 years of age or older. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a minor in violation of applicable law, we will take reasonable steps to delete such information.

7. Updates and Changes

We may update this Privacy Notice from time to time to reflect changes in our practices or for legal reasons. We will post any changes here or on a similarly accessible page on lttl.com.

8. Consumer Health Data

This section supplements our Privacy Notice and applies to personal data defined as "consumer health data" under applicable U.S. state laws (including, where applicable, the Washington My Health My Data Act, Nevada SB 370, the CCPA/CPRA, the Colorado Privacy Act, the Virginia CDPA, and similar laws). Much of our processing of consumer health data is also subject to HIPAA.

We may collect categories of consumer health data including health conditions, treatments, diagnoses, medications, vital signs and symptoms, reproductive or sexual health information, and other information that may be used to infer health status — only as needed to support the services you request.

9. Contacting Us

If you have questions about this Privacy Notice or wish to submit a privacy request, please email us at info@lttl.com. You also have the right to make privacy requests directly to your Healthcare Provider as described in their privacy policies.

10. HIPAA Notice of Privacy Practices

Your Information. Your Rights. Our Responsibilities.

This section describes how medical information about you may be used and disclosed, and how you can get access to this information. Please review it carefully.

Who We Are

This notice describes the privacy practices of Lttl, operated by The Commerce Group Holdings, LLC ("Lttl," "we," "our," or "us"), and the affiliated independent medical groups and licensed clinicians who provide clinical services to you through the Lttl platform (collectively, the "Lttl Affiliated Practices"). For purposes of complying with HIPAA, the Lttl Affiliated Practices may share your protected health information (PHI) with each other as needed to carry out treatment, payment, and health care operations (TPO). The Lttl Affiliated Practices have a designated single Privacy Officer responsible for HIPAA compliance.

Your Rights

You have the right to:

• Get a copy of your paper or electronic medical record
• Correct your paper or electronic medical record
• Request confidential communication
• Ask us to limit the information we share
• Get a list of those with whom we've shared your information
• Get a copy of this privacy notice
• Choose someone to act for you
• File a complaint if you believe your privacy rights have been violated

You have some choices in the way that we use and share information as we:

• Tell family and friends about your condition
• Provide disaster relief
• Provide mental health care
• Market our services and sell your information
• Raise funds — We may contact you to support our fundraising efforts. You have the right to opt out of future fundraising communications at any time, and choosing not to receive them will not affect your care. To opt out, contact our Privacy Office by emailing privacy@lttl.com.

Our Uses and Disclosures

We may use and share your information without your permission as we:

• Treat you
• Run our organization
• Bill for your services
• Help with public health and safety issues
• Do research
• Comply with the law
• Respond to organ and tissue donation requests
• Work with a medical examiner or funeral director
• Address workers' compensation, law enforcement, and other government requests
• Respond to lawsuits and legal actions

Your Rights in Detail

When it comes to your health information, you have certain rights. You can exercise any right below by emailing privacy@lttl.com.

Get an electronic or paper copy of your medical record. You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your medical record. You can ask us to correct health information about you that you think is incorrect or incomplete. We may say "no" to your request, but we'll tell you why in writing within 60 days.

Request confidential communications. You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say "yes" to all reasonable requests.

Ask us to limit what we use or share. You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say "no" if it would affect your care. If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say "yes" unless a law requires us to share that information.

Get a list of those with whom we've shared information. You can ask for a list (accounting) of the times we've shared your health information for six years prior to the date you ask, who we shared it with, and why. We'll provide one accounting a year for free, but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice. You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.

File a complaint if you feel your rights are violated. You can complain if you feel we have violated your rights by contacting us using the information below. You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in your care
• Share information in a disaster relief situation

If you are not able to tell us your preference, for example, if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases, we never share your information unless you give us written permission:

• Marketing purposes — we will obtain your HIPAA authorization before using your information for marketing
• Sale of your information
• Psychotherapy notes, except where permitted by law or with your written authorization

In the case of fundraising: We may contact you for fundraising efforts, but you can tell us not to contact you again.

How We Typically Use or Share Your Health Information

Treat you. We can use your health information and share it with other professionals who are treating you. Example: A clinician treating you for a condition asks another clinician about your overall health condition.

Run our organization. We can use and share your health information to run our practice, improve your care, and contact you when necessary. We might send you appointment reminders by email or text, or leave messages on an answering machine. Electronic communications involve the risk of unauthorized access. By providing your contact information, you acknowledge and accept these risks. We use artificial intelligence (AI) and machine learning tools to analyze health information to identify ways to improve our services, enhance our clinical workflows, and refine our AI systems for better performance. These tools are used in compliance with HIPAA and other applicable laws. They do not replace a licensed clinician's clinical judgment or decision making.

Bill for your services. We can use and share your health information to bill and get payment from health plans or other entities. Example: We give information about you to your health insurance plan so it will pay for your services.

How Else Can We Use or Share Your Health Information?

We are allowed or required to share your information in other ways — usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.

Help with public health and safety issues such as preventing disease, helping with product recalls, reporting adverse reactions to medications, reporting suspected abuse, neglect, or domestic violence, and preventing or reducing a serious threat to anyone's health or safety.

Do research. We can use or share your information for health research.

Comply with the law. We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we're complying with federal privacy law.

Respond to organ and tissue donation requests. We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director. We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

Address workers' compensation, law enforcement, and other government requests for workers' compensation claims, law enforcement purposes, health oversight activities, and special government functions such as military, national security, and presidential protective services.

Respond to lawsuits and legal actions. We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. Notification will be provided without unreasonable delay, but no later than 60 days after discovery, as required by law.
• Where state laws require greater privacy protections than HIPAA, we will follow state law.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know by sending a notice in writing to our Office of Privacy if you change your mind.

For more information, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Changes to the Terms of This Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.

HIPAA Contact

Privacy questions or requests: privacy@lttl.com