Privacy Policy

PRIVACY POLICY

Latest Revision:      December 15, 2025

Introduction

This Privacy Policy pertains to the operations of JRNYS Wellness, Inc. and its affiliates ("KINSYN” or "us"), and explains how KINSYN collects, uses, and discloses personal information through our website at https://kinsyn.com and any mobile application we operate and any social media webpage we establish that contains a link to this Privacy Policy (collectively referred to as the "Websites"). Your use of the Websites, their components, our content ("Content"), and products or services offered by KINSYN (collectively, the "Platform Services") is governed by this Privacy Policy, unless explicitly stated otherwise. KINSYN is the data controller of the personal information collected under this Privacy Policy. As used in this Privacy Policy, “personal information” means information that relates to an identified or reasonably identifiable natural person.

Telemedicine services provided through our Websites (“Telemedicine Services”) are provided by medical practitioners employed by, or under contract with, JRNYS Medical, P.A., a Delaware professional corporation, other healthcare providers, medical groups, and/or pharmacies (“Providers”). In some instances, your personal information may constitute Protected Health Information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). In those instances, please review our HIPAA Notice of Privacy Practices which can be found here, which is supplemented by this Notice. 

1. Collection of Personal Information

a. Directly Provided Information: We gather personal information and sensitive personal information that you directly provide to us.

i. When you communicate with us or sign up for a subscription for the Platform Services, we collect identifiers (such as your name and email address) and commercial information (such as contact details including your phone number and billing and physical addresses);

ii. When you use the Platform Services, sign up for Telemedicine Services, or take one our quizzes, we collect demographic data, such as gender, date of birth, and zip code;

iii. When you register for the Platform Services or purchase Telemedicine Services, we collect transaction information (such as payment card number) commercial information (such as transaction details), and identifiers (such as a copy of your ID (such as driver’s license) and a selfie), in order to verify your identity;

iv. When you use the Platform Services, we collect any audio or visual information (such as content, images, and other files or information) you upload or submit; and we may collect the following categories of sensitive personal information (to the extent provided by you):

  • account credentials together with associated passwords;
  • content of communications that may contain sensitive information;
  • information about your health; and/or
  • information about your sexual orientation or sex life.

b. Information Posted to Social Media: If you post information on a webpage we establish on a social media platform, we may use the information you provide for purposes of providing a response, to promote our business and the Platform Services, and otherwise in the normal course of our business operations. We may collect identifiers (such as your social media username) and other personal information that you have made available to us through the webpage we established on the social media platform, in accordance with the platform rules and/or applicable law. Note that the third-party operators of social media websites also receive such information, and their use of your personal information is governed by their own privacy policies.

c. Automatically Collected Information – Cookies and Similar Technologies: When you utilize our Platform Services, we and third-party service providers, such as analytics providers (including Google Analytics) and advertising services, collect information by automated means. For instance, we may collect:

  • Identifiers and device data. Our web servers log your IP address and device information when you visit our Websites. This includes device identifiers (e.g., MAC address), device type, operating system, browser, software details, and settings.
  • Geolocation data. Depending on device and app settings, we may collect approximate geolocation data from your device, such as your IP address.
  • Internet or other electronic network activity information. We or analytics providers may automatically record and/or analyze your activities, including source URL, viewed pages, time spent on pages, access times, and other actions on our Websites.
  • Inferences and generated information. We may draw inferences from collected data to deduce probable preferences or traits. For instance, we may infer likely general geographic location from your IP address.

We or third parties may employ cookies, pixels, tags, and similar technologies in connection with the Platform Services, collecting data like usage details, identifiers, and device information. Cookies are small files stored by your browser on your device, containing alphanumeric strings for identification. Our Websites also interact with third-party content hosting servers which may collect associated browser or device information.

We and our third-party partners, such as analytics providers (including Google Analytics) and advertising partners, utilize these technologies to gather personal information, track your activities, analyze website/app performance, deliver tailored advertising, combat fraud, and otherwise. Data collected or inferred may be shared with third parties for these purposes. Please see our Cookie Policy below for more details.

As indicated above, we use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit https://tools.google.com/dlpage/gaoptout.

If your browser offers you the ability to use Global Privacy Control (GPC) to communicate your privacy preferences to us, we honor such signals by opting you out of or restricting cookie technology that may otherwise constitute targeted advertising or a “sale” or “sharing” for targeted advertising under state privacy laws.

d. Information Provided by Third Parties: In some cases we may obtain personal information from third-party sources such as marketing partners.

 

2. Use of Information

We utilize the personal information we gather for the purposes outlined in this Privacy Policy. We may use any of the categories of personal information described above for the following purposes:

a. Product and Service Delivery: To provide and deliver the Platform Services, including troubleshooting, ensuring smooth navigation through the Platform Services, confirming your location, and enhancing and personalizing the Platform Services.

b. Business Operations: To operate our business, such as billing, processing payments, accounting, managing your account, enhancing internal operations, securing systems, detecting fraudulent or illegal activities, verifying identity, and meeting legal obligations.

c. Product Improvement, Development, and Research: To develop, test, or improve the Content, features, products, or services offered through the Platform Services, to create new products or services, and to analyze traffic and user behavior for insights.

d. Personalization: We use personal information to understand user preferences to enhance the user experience and enjoyment of our Platform Services.

e. Customer Support: To provide customer support, fulfilling requests, and responding to inquiries and to handle orders for products or services on behalf of users.

f. Communications: We use personal information to send information related to KINSYN and/or the Platform Services, including confirmations, invoices, technical notices, updates, security alerts, support, and administrative messages.

g. Marketing: We use personal information to communicate to you about new services, offers, promotions, rewards, contests, events, and other information regarding our Platform Services and Telemedicine Services and those of selected partners.

h. Advertising: We use personal information to promote and market KINSYN, the Platform Services, and related products or services.

i. Data De-identification: We may de-identify information and use such de-identified information for any lawful purpose.

3. Disclosure of Information

We may disclose personal information for our business and commercial purposes, including in the following circumstances:

a. Service Providers: We disclose personal information with service providers, vendors or agents who work on our behalf to provide the Platform Services. For instance, third-party companies assisting in customer service or safeguarding our systems may require access to personal information for their respective functions.

b. Financial Services & Payment Processing: When you provide payment information, such as for purchases, we disclose payment and transactional data to banks and relevant entities for payment processing, fraud prevention, credit risk assessment, analytics, and related financial services.

c. Marketing/Ad Partners and Third-Party Analytics Providers: Personal information may be shared with marketing and advertising partners and third-party analytics providers.

d. Affiliates: Personal information may be accessed by our affiliates when necessary to provide the Platform Services or operate our business.

e. Corporate Transactions: Personal information may be disclosed in corporate transactions, such as mergers, acquisitions, bankruptcy, or sale of a portion of our business; personal information may be shared with the other parties and advisors involved under an obligation of confidentiality in connection with the negotiation of such transaction, and your personal information may be transferred as part of such a transaction (subject to compliance with applicable laws).

f. Legal and Law Enforcement: We share personal information with law enforcement, the courts, our advisors, attorneys, and others who participate in legal processes or proceedings, if we believe doing so is required or appropriate to: comply with legal requirements and law enforcement requests (such as a court order or subpoena); comply with legal process (such as discovery); or protect your, our, or others’ rights, property, or safety.

g. Security and Safety: Personal information may be disclosed to protect customers and prevent fraud, ensure the security of our Platform Services and enforce agreements, terms, and policies.

We may also disclose de-identified information in accordance with applicable law.

4. Choice and Control of Personal Information

We offer various ways for you to control the personal information we possess, including choices about its use. 

  • Information Related to Your Account. For subscribers, if you wish to access, copy, correct, or delete your personal information held by us, you can do so through your account.
  • Email Marketing. You can opt out of promotional or marketing emails by following the instructions in the email message or by contacting us.
  • SMS Text Messages. Consent to receive automated marketing text messages is not a condition of any purchase. You can opt-out of receiving text messages by responding to any of our text messages with any of the following replies or words of similar effect: STOP, END, CANCEL, UNSUBSCRIBE, REVOKE, OPT-OUT, or QUIT. Following a request to opt-out of receiving text messages, you may receive a message from us confirming your opt-out. Please note that if, after opting out, you subsequently consent to receiving text messages, we will start sending you text messages again until and unless you opt-out again. In addition, we may send you informational texts about your order, shipping, or delivery status, subscription, and payment status, and we may send you notifications  by text from our medical care teams if you provide your mobile number for such purposes.

5. Privacy Rights Under State General Privacy Laws

The laws of certain US states provide residents with specific rights regarding their personal information. For purposes of this Section, “you” refers only to consumers who are residents of a state with an applicable state general privacy law. This Section describes the rights that you may have and explains how to exercise those rights. If you are a California resident, see our Supplemental California Notice section below.

Access to Certain Information

You may have the right to request that we disclose certain information to you about our collection and use of your personal information. 

Deletion and Correction Request Rights

You may have the right to request that we correct inaccurate personal information and, in certain circumstances, delete the personal information that we collected from you and retained, subject to certain exceptions. When applicable, if we are able to confirm your request, we will delete or correct your personal information in our records, unless an exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to provide a service that you requested, detect security incidents, engage in public or peer-reviewed research in the public interest, or comply with a legal obligation.

Personal Information Sale and Sharing Opt-Out and Opt-In Rights

You may have the right to direct us not to share your personal information for purposes of targeted advertising (or otherwise use it for targeted advertising) and not to sell your personal information. To the extent that any cookies or related technologies on the Websites may constitute such sharing or sale, you may opt-out using our cookie management tool. 

Right to Limit Use of Sensitive Personal Information

You may have the right to request that we limit use of your sensitive personal information to certain purposes allowed by law. 

Right to Opt Out of Automated Decision-making

You may have the right to opt-out of automated decision-making for profiling purposes in certain instances where such processing would produce legal or other similarly significant effects. At this time, we do not use personal information to make automated decisions about individuals in any situations which would give rise to a legal right to opt out.

Exercising Your Rights

To exercise the rights described above, please submit a request to us by using our cookie management tool (for cookies and related technologies), or calling [(512) 960-1075]. 

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or their authorized representative; and
  • 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. We will only use personal information provided in your request to verify your identity or authority to make the request and as otherwise necessary for our compliance with applicable law.

Making a request to exercise the above privacy rights does not require you to create an account with us.

Response Timing and Format

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. If data portability is a legal requirement, we will endeavor to select a format that is technically feasible and readily useable.

Our response will explain any reasons we cannot fully comply with a request, if applicable.

Right to Request Further Review

You may have the right to appeal our decision if we deny your request. Send an email to support@kinsyn.com or insert other email address to be used in relation to data subject requests] if you would like to request further review.  

Non-Discrimination

We will not discriminate against you for exercising any of your rights under state privacy laws. 

6. Supplemental California Notice

This Section further describes our processing of personal information of California residents as contemplated under California law. Please also refer to the preceding Section (above) for a description of rights that California residents have and how to exercise those rights.

 Identifiers:

  • Source: Directly from you, from your posts to social media, and automatically collected through our Websites
  • Purpose of collection and use: See Sections 1.a, 1.c, 1.d, 2.a-i
  • Categories of parties with whom information is sold or shared: We only sell or “share” information in connection with certain third-party providers of cookies or similar technologies as described above and further set forth in the cookie management tool accessible through the “Your Privacy Choices” link in the footer of the Websites
  • Categories of parties with whom information is disclosed: See Sections 3.a-h

Commercial Information:

  • Source: Directly from you
  • Purpose of collection and use: See Section 1.a.i, 1.a.iii, Section 2.a-f
  • Categories of parties with whom information is sold or shared: N/A
  • Categories of parties with whom information is disclosed: See Sections 3.a-b, 3.d-h

Internet or other electronic network activity information:

  • Source: Automatically collected from our Websites
  • Purpose of collection and use: See Section 1.d-e, 2.a-i
  • Categories of parties with whom information is sold or shared: We only sell or “share” information in connection with certain third-party providers of cookies or similar technologies as described above and further set forth in the cookie management tool accessible through the “Your Privacy Choices” link in the footer of the Websites
  • Categories of parties with whom information is disclosed: See Sections 3.a-h

Transaction information:

  • Source: Directly from you
  • Purpose of collection and use: See Section 1.a.iii, Section 2.a-f
  • Categories of parties with whom information is sold or shared: N/A
  • Categories of parties with whom information is disclosed: See Sections 3.a-b, 3.d-h

Geolocation data:

  • Source: Automatically collected from our Websites
  • Purpose of collection and use: See Section 1.d, 2.a-i
  • Categories of parties with whom information is sold or shared: We only sell or “share” information in connection with certain third-party providers of cookies or similar technologies as described above and further set forth in the cookie management tool accessible through the “Your Privacy Choices” link in the footer of the Websites
  • Categories of parties with whom information is disclosed: See Sections 3.a-h

Demographic information:

  • Source: Directly from you
  • Purpose of collection and use: See Section 1.a.ii, Section 2.a-f, 2.i
  • Categories of parties with whom information is sold or shared: N/A
  • Categories of parties with whom information is disclosed: See Sections 3.a-b, 3.d-h

Audio and visual information:

  • Source: Directly from you
  • Purpose of collection and use: See Section 1.a.iv, Section 2.a-f
  • Categories of parties with whom information is sold or shared: N/A
  • Categories of parties with whom information is disclosed: See Sections 3.a-b, 3.d-h

Sensitive information:

  • Source: Directly from you
  • Purpose of collection and use: See Section 1.a.v, Section 2.a-b, 2.e, 2.f
  • Categories of parties with whom information is sold or shared: N/A
  • Categories of parties with whom information is disclosed: See Sections 3.a, 3.d-h

California “Shine the Light” law

Please note, we do not rent, sell, or share “personal information” as defined by California Civil Code §1798.83 about you that we collect on the Websites with unaffiliated third parties for their direct marketing purposes. 

7. Data Retention

We retain your information as long as necessary for various purposes, including legal compliance, dispute resolution, agreement enforcement, and provision of services. 

Individual pieces of personal information may exist in different systems that are used for different business or legal purposes. A different maximum retention period may apply to each use case of the information. Certain individual pieces of information may also be stored in combination with other individual pieces of information, and the maximum retention period may be determined by the purpose for which that information set is used.

8. Children

Our Platform Services are intended for use by individuals aged 18 years or older, or as stipulated by applicable state laws. If we become aware that we have gathered personal information from someone under 18, we will make reasonable efforts to cease further use of such information.

9. Links to Unaffiliated Third-Party Websites

Our Platform Services and Telemedicine Services may contain links to unaffiliated third-party websites. This Privacy Policy does not apply to the practices of such other websites, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those websites.

10. Information Security

We take reasonable measures to protect information, in accordance with this Privacy Policy and in accordance with information security requirements imposed by applicable law. However, you are responsible for securing your account. Note that certain aspects of Internet communications are inherently not completely secure.

11. Contact Us

If you have questions about this Privacy Policy, contact us at support@kinsyn.com 

12. Posting of a Revised Privacy Policy

We may make changes to this Privacy Policy from time to time, and the revised version will be effective when it is posted and will apply to personal information received after that date. If we make any material changes, we will provide notice of such changes on our Websites or in any other pertinent location where this Privacy Policy may be posted for a reasonable period of time (which we estimate will be approximately two weeks). We encourage you to review this Privacy Policy periodically, especially if you do not use our Platform Services or Telemedicine Services regularly.

 

COOKIE POLICY

We use or permit cookies, pixels, tags, and similar technologies (referred to herein as “cookies”) to facilitate and improve the performance and security of our Websites and to enhance user experience.

The Websites may utilize or permit several different categories of cookies, as follows:

  • Essential cookies – Some cookies may be essential for the proper operation of the Websites. For example, they may facilitate page navigation or assist with security checks.
  • Functional cookies – These cookies allow us to remember your preferences and allow us to make the website experience better for you.
  • Performance/analytics cookies – These cookies allow us to analyze how visitors use our Websites and to measure website performance. This allows us to provide a quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of what content is popular, or to learn what links between pages are most effective or why some pages are receiving error messages.
  • Advertising cookies – These cookies may be used to highlight content or services that we think will be of interest to you based on your use of the Websites. 

Use of Cookies on Our Websites

We do use or allow certain third parties to serve cookies on the Websites. We may allow third parties to serve cookies to help identify fraudulent or automated traffic on our Websites. In addition, third parties that provide content feeds may serve cookies. We may use third-party cookies to help us with market research, improving functionality, and enforcing website terms and policies. For example, like many companies, we use Google Analytics to help us evaluate our Website traffic. You can see how Google Analytics uses cookie information across various websites by visiting https://policies.google.com/technologies/partner-sites, or any successor webpage that Google may provide. In addition, we may permit use of cookies for targeted advertising purposes.

Information about specific third-party cookies used on the Websites may be found via the "Your Privacy Choices" link on our Websites’ homepages.]

Specific Cookies and Associated Privacy Practices <

p>The Websites may use and permit cookies and pixels from the following providers:

  • Analytics and performance

Cookie Provider: Google Analytics (_ga,_gid, _gat,  gcl_au)

Privacy Notice of Provider: https://policies.google.com/privacy?hl=en 

  • Advertising and marketing

Cookie Provider: Google Ads and Doubleclick (gclid, gbraid, wbraid, efTransactionId, utm_source, utm_medium, utm_campiagn)

Privacy Notice of Provider:  https://policies.google.com/privacy?hl=en 

Cookie Provider: Meta Pixel

Privacy Notice of Provider: https://www.facebook.com/privacy/policy/ 

  • Cart

Cookie Provider: Guest_cart_id

Privacy Notice of Provider: https://craftcms.com/privacy 

  • Advertising and marketing

Cookie Provider: Facebook/Meta (_fbp, _fbc,fr)

Privacy Notice of Provider: https://www.facebook.com/privacy/policy/ 

  • Analytics

Cookie Provider: Rudderstack (rl_user_id, rl_trait, rl_anonymous_id, rl_page_init_referring_domain, rl_page_init_referrer, rl_session)

Privacy Notice of Provider:  https://www.rudderstack.com/privacy-policy/

  • Analytics

Cookie Provider: Klaviyo (_kla_id)

Privacy Notice of Provider: https://privacy.klaviyo.com/policies/en/

  • Authentication 

Cookie Provider: Сraft CMS (1031b8c41dfff97a311a7ac99863bdc5_identity, 1031b8c41dfff97a311a7ac99863bdc5_username, craftcms, PHPSESSID

Privacy Notice of Provider:  https://craftcms.com/privacy

  • Advertising and marketing

Cookie Provider:  TikTok (_ttp, ttcsid)

Privacy Notice of Provider: https://www.tiktok.com/legal/page/row/privacy-policy/en 

  • Analytics

Cookie Provider: Sentry (sentry-sc)

Privacy Notice of Provider: https://sentry.io/privacy/

 

Cookie Options

Your browser may allow you to disable certain cookies. Moreover, as stated above in our Privacy Policy, if your browser offers you the ability to use a Global Privacy Control (“GPC”) to communicate your privacy preferences to us, we honor such signals by opting you out of or restricting cookie technology that may otherwise constitute “sharing” for targeted advertising or a “sale” under state privacy laws. Also, the third party listed for a given cookie may provide an opt out tool for that cookie. You can also opt-out of certain cookies by using the “Your Privacy Choices” link on our Websites’ homepages. To learn more about Google Analytics and how to opt-out, please visit https://tools.google.com/dlpage/gaoptout. Note that disabling cookies may in some instances impact the functionality of our Websites.

Web browsers may allow you to change your cookie settings. These settings will typically be found in the ‘options’ or ‘preferences’ menu of your browser.

Also, you may learn more about advertising networks and opt-out of receiving personalized advertisements on a particular browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to their opt-out sites are set forth below.

Please note that these controls are specific to your device or browser. Also, when you opt out of personalized advertising, you may continue to see online advertising on our Websites and/or our ads on other websites and online services. Because many opt-outs themselves use a cookie to effectuate an opt-out preference, you may need to opt-out again if you clear cookies on your browser.

Changes to this Cookie Policy

We may revise this Cookie Policy from time to time in order to reflect changes in our use of cookies, changes in the law, changes in our services, or best practices. We encourage you to review this Cookie Policy periodically.