PRIVACY POLICY

Effective Date: January 28, 2026

1. INTRODUCTION

This Privacy Policy describes how System Labs ("System Labs," "we," "us," or "our") collects, uses, and shares information about you when you visit our website (the "Site"). By using the Site, you consent to the practices described in this Privacy Policy.

2. DEFINITIONS

As used in this Privacy Policy:

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

"Processing" means any operation or set of operations performed on Personal Information, whether or not by automated means.

"Service Providers" means third-party entities that process Personal Information on our behalf.

"Site" means the website operated by System Labs, including all features, functionality, and content available through the domain and all related subdomains.

3. INFORMATION WE COLLECT

3.1 Personal Information

We may collect personal information that you voluntarily provide to us, such as:

• Contact information (name, email address, phone number, postal address)
• Account information (username, password)
• Profile information (preferences, interests)
• Payment information (credit card details, billing address)
• Communications (emails, chat messages, feedback)
• Any other information you choose to provide

3.2 Automatically Collected Information

When you visit the Site, we automatically collect certain information about your device, including:

• Device information (browser type, operating system, device type)
• Usage data (pages visited, time spent on pages, referring website)
• Location data (IP address, general geographic location)
• Log data (error reports, activity patterns)

3.3 Cookies and Similar Technologies

What Are Cookies

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information.

Types of Cookies We Use

• Essential Cookies: Required for the Site to function properly. These include cookies that enable you to log into secure areas of the Site or use essential features. These cookies do not gather any information about you that could be used for marketing or remembering where you've been on the internet. These cookies cannot be disabled.

• Preference Cookies: Enable the Site to remember information that changes the way the Site behaves or looks, like your preferred language or the region you are in. These cookies can be disabled, but this may affect your user experience.

• Analytics Cookies: Help us understand how visitors interact with the Site by collecting and reporting information anonymously. We use Google Analytics, which places cookies on your device to help us analyze how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States.

• Marketing Cookies: Used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user. We use cookies from the following third-party advertising partners: Google Ads and Facebook Pixel.

Specific Cookie Technologies We Use

Your Cookie Choices

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. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Site.

How to Opt Out of Cookies: You can manage your cookie preferences by:

1. Adjusting your browser settings to refuse cookies
2. Clicking on the "Cookie Preferences" link in the footer of our Site
3. Using the opt-out mechanisms provided by our analytics providers:
• Google Analytics: https://tools.google.com/dlpage/gaoptout

4. USE OF ARTIFICIAL INTELLIGENCE

System Labs uses artificial intelligence ("AI") technologies to enhance our services, improve user experience, and process information. This may include using AI to:

• Analyze user interactions with the Site
• Process and respond to user inquiries
• Assist in content generation and management
• Enhance security and fraud detection
• Provide the services to you
• Improve our services and develop new features

By using the Site or Services, you acknowledge and consent to our use of AI technologies as part of our services. We implement appropriate safeguards when using AI, including human review of AI-generated content where appropriate. However, you understand that AI-generated content or responses may not always be perfect or complete.

We do not use AI to make automated decisions that significantly affect you without human oversight.

5. HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Provide, maintain, and improve the Site
• Process transactions and send related information
• Respond to comments, questions, and requests
• Send information including confirmations, technical notices, updates, security alerts, and support and administrative messages
• Communicate about products, services, offers, promotions, and events
• Monitor and analyze trends, usage, and activities in connection with the Site
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Protect the rights and property of System Labs and others
• Comply with legal obligations
• Improve our services and develop new features

6. INFORMATION SHARING

We may share your information with:

• Service providers who perform services on our behalf (such as payment processors, hosting providers, analytics providers)
• Third-party pharmacies, including The Pharmacy Hub (https://thepharmacyhub.com/), for fulfillment of prescriptions and products
• Professional advisors, such as lawyers, bankers, auditors, and insurers
• Government authorities if required by law or to protect our rights
• Business partners with your consent
• Other users, with your consent
• In connection with a business transaction (such as a merger, acquisition, or sale of assets)

6.1 Categories of Service Providers

We share information with the following categories of service providers:

• Cloud storage providers
• Payment processors
• Analytics providers
• Customer support services
• Email and communication providers
• Marketing and advertising partners
• Security and fraud prevention services
• Third-party pharmacies and fulfillment partners

6.2 Information Sharing for Business Purposes

We may share your personal information for the following business purposes:

• Auditing related to a current interaction with you
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity
• Debugging to identify and repair errors
• Short-term, transient use
• Performing services on our behalf
• Internal research for technological development
• Verifying or maintaining the quality or safety of our services
• Fulfillment of prescriptions and product orders through third-party pharmacies

6.3 Pharmacy Partners

When you place an order for prescription medications or products, we share necessary information with our pharmacy partners, including The Pharmacy Hub, to fulfill your order. This may include:

• Your name and contact information
• Prescription information
• Shipping address
• Payment information (as necessary for order processing)

Our pharmacy partners are bound by their own privacy policies and applicable pharmacy regulations, including HIPAA where applicable. We encourage you to review the privacy policies of our pharmacy partners.

We do not sell your personal information to third parties as "selling" is traditionally defined. We only share your information with third-parties as necessary to provide the Services to you. All above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. For the avoidance of doubt, we do not share text messaging originator opt-in data and consent with any third parties for the purpose of third-party marketing. Some state laws define "selling" broadly to include certain data sharing practices for advertising or marketing purposes. To the extent these laws apply, you have the right to opt out of such "selling" as described in the Your Privacy Rights section below.

7. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. These measures include:

• Encryption of sensitive information in transit and at rest
• Secure servers and networks with firewalls and intrusion detection systems
• Regular security assessments and penetration testing
• Employee training on security and privacy practices
• Access controls limiting employee access to personal information
• Physical security measures for our facilities
• Regular backups and disaster recovery planning

However, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk.

8. DATA BREACH NOTIFICATION

In the event of a data breach that compromises your personal information, we will:

• Notify you via email and/or prominent notice on our Site within 72 hours of discovering the breach
• Include information about what happened, what information was involved, what we are doing to investigate and mitigate the breach, and what you can do to protect yourself
• Notify relevant regulatory authorities as required by applicable law
• Provide credit monitoring services if appropriate based on the nature of the compromised information

9. DATA RETENTION

We will retain your personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the Text Message services.

Specific retention periods for different categories of personal information:

• Account information: For the duration of your account plus 7 years
• Transaction information: 7 years for tax and accounting purposes
• Communications with us: 3 years from the date of communication
• Marketing preferences: Until you opt out or request deletion
• Device and usage data: 13 months

When we no longer need to retain your personal information, we will securely delete or anonymize it. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. YOUR PRIVACY RIGHTS

10.1 General Rights

Regardless of your location, you may contact us at any time to:

• Request access to your personal information
• Request correction of your personal information
• Request deletion of your personal information
• Object to our processing of your personal information
• Request that we restrict our processing of your personal information
• Request data portability
• Opt out of marketing communications

To exercise these rights, please contact us at support@systemlabs.com.

10.2 State-Specific Rights

As we grow, we may become subject to various state privacy laws. When applicable based on our operations, revenue, or data processing activities, we will comply with state-specific privacy requirements and update this policy accordingly.

10.3 Opt-Out Procedures

Marketing Communications

You can opt out of receiving marketing communications from us by:

• Clicking the "unsubscribe" link in any marketing email we send
• Emailing us at support@systemlabs.com with the subject line "Opt Out of Marketing"
• Updating your communication preferences in your account settings

Information Sharing

To opt out of certain information sharing practices:

1. Email us at support@systemlabs.com with the subject line "Opt Out of Information Sharing"
2. Specify which types of sharing you wish to opt out of
3. Include your full name and contact information

Targeted Advertising

To opt out of targeted advertising:

1. Visit the Digital Advertising Alliance's opt-out portal at www.aboutads.info/choices
2. Visit the Network Advertising Initiative's opt-out portal at www.networkadvertising.org/choices
3. Adjust your device settings to limit ad tracking:
• On iOS devices: Settings > Privacy > Tracking > Toggle off "Allow Apps to Request to Track"
• On Android devices: Settings > Google > Ads > Opt out of Ads Personalization

11. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

You must be located in the United States to be a user of System Labs' services. However, if you are located outside the United States and choose to provide information to us, please note that we transfer the information to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

For transfers from the United States to other countries, we implement appropriate safeguards, which may include:

• Standard contractual clauses approved by relevant authorities
• Binding corporate rules for transfers to entities within our corporate group
• Derogations for specific situations, such as your explicit consent
• Privacy Shield certification, where applicable

12. AUTOMATED DECISION MAKING

We may use automated decision-making processes for the following purposes:

• Fraud detection and security monitoring
• Customizing content and recommendations based on your browsing history and preferences

These automated processes may analyze your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. To exercise this right, please contact us at support@systemlabs.com.

13. CHILDREN'S PRIVACY

The Site is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@systemlabs.com.

14. THIRD-PARTY LINKS

The Site may contain links to third-party websites and services, including our pharmacy partners such as The Pharmacy Hub (https://thepharmacyhub.com/). We are not responsible for the content or privacy practices of those websites or services. We encourage you to read the privacy policies of those websites.

15. CHANGES TO OUR PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this Privacy Policy. For material changes, we will provide additional notice, such as via email or a prominent notice on our Site. You are advised to review this Privacy Policy periodically for any changes.

16. CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us at:

System Labs
226 Roosevelt Way
San Francisco, CA 94114
Email: support@systemlabs.com