Ezra Privacy Policy

Last Updated: 06/17/2025

Introduction

Ezra AI, Inc. (“Ezra AI”), Ezra Health of Florida, PLLC (“Ezra Health”) and their respective subsidiaries and affiliates (including Function Health, Inc.) (collectively, “Ezra,” “we,” “us,” or “our”) have prepared this Privacy Policy to explain what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our practices, all in the context of your use of the Service (as defined in the Terms of Service). In connection with providing the Service, we provide and make available certain websites, including, without limitation, www.ezra.com (collectively, the “Site”), cloud platforms, and mobile applications and related technologies (the “Mobile App”), including any updated or new feature, functionality or technology.

This Privacy Policy is incorporated into and forms part of our Terms of Service. Capitalized terms used herein but not defined shall have the meanings ascribed to them in our Terms of Service and our Telehealth Authorization.

Before using the Service or submitting any Personal Information to us, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

Personal Information We Collect

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

Personal Information You Provide: We collect the following categories of Personal Information from you when you register for an account, visit or use the Site or Service, or contact Ezra:

• Identification Information: We collect your name, email address, phone number, mailing/billing addresses, and account information (including user name and password).
• Financial Information: Our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.
• Health Information: We collect health information you provide when you register and use the Service to request, schedule, and obtain a scan. This may include your medical history, including the results of any questionnaires, surveys, information requests, interviews, results, or other documentary, text, video, or audio interactions related to the provision of health services. Please see the “Protected Health Information” section below for more information on our handling of health information subject to applicable privacy laws.
• Photo/Visual Information: We may collect photos or videos you choose to provide to us as a part of the Services.
• Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, quizzes, surveys or requests for market research seeking your opinion and feedback. Providing Communication Information is optional to you.
• Commercial Information: We will retain a history of your transactions through the Service, as well as the products or services you browse and/or purchase using the Service.
• Demographic Information: We may collect your age, gender, income level, and other demographic information.
• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Protected Health Information: Some of the Personal Information processed by Ezra in connection with the Service from you, Imaging Locations that perform your scans, genetic testing partners, or other health care providers may be subject to laws and regulations, such as rules issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH), that govern providers’ use and disclosure of certain individually identifiable health-related Personal Information (“Protected Health Information”). When Ezra receives Protected Health Information, it does so as a “business associate” of certain health care providers under an agreement that, among other things, prohibits us from using or disclosing the Protected Health Information in ways that are not permissible by the health care provider itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the Protected Health Information. When we act as a business associate, we may be subject to certain laws and regulations, including certain HIPAA rules, that govern our use and disclosure of Protected Health Information and that may be more restrictive than otherwise provided in this Privacy Policy.

In certain instances, and with your consent, we may process “genetic information,” as defined in the Genetic Information Nondiscrimination Act of 2008 (GINA). GINA generally makes it illegal for health insurance companies, group health plans, and most employers to seek your genetic information without your consent, and to discriminate against you based on your genetic information. GINA does not protect you from discrimination with regard to life insurance, disability insurance, long-term care insurance, or military service. More information about GINA is available at http://www.genome.gov/. In addition, there are laws in certain states that prohibit discrimination against an individual based on genetic data. Consistent with GINA and other applicable laws, we will never share your genetic information with health insurance providers or employers.

Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

• Log Data: Information that your browser automatically sends whenever you visit the Service. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service.
• Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
• Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
• Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
• Location Information: We derive a rough estimate of your location from your IP address when you use the Service.
• Email Open/Click Data: We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Personal Information Collected from Third Parties: You may enable or log in to the Service via various social media and social networking services (“Social Media Sites”), or enable sharing of certain User Content or Service Content to, on or with Social Media Sites. By logging in or directly integrating these Social Media Sites into the Service, we may make your online experiences richer and more personalized. To take advantage of this feature and capabilities, we may ask you to authenticate, register for or log into Social Media Sites on the websites of their respective providers. As part of such integration, the Social Media Sites may provide us with access to certain information, including Personal Information, that you have provided to such Social Media Sites. This Personal Information may include your name and public profile information, and we will use, store and disclose such information in accordance with this Privacy Policy. We also may receive your Personal Information from Imaging Locations and other partners so that we may contact you about and provide you with the Service.

Derived Information: We may infer information about you, your preferences, and your health based on the Personal Information, including Health Information, we collect about you.

Cookies: We use cookies to operate and administer our Service, gather usage data on our Service, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service and you may not be able to benefit from the full functionality of the Service.

Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Service on your mobile device, you may not be able to control tracking technologies through the settings.
Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.

How We Use Personal Information

We may use Personal Information for the following purposes:

• To provide the Service and any related customer support;
• To maintain your account, including offering functionalities such as the ability to save user preferences and account or user history;
• To respond to your inquiries, comments, feedback, or questions;
• To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To maintain and improve the Service;
• For marketing or advertising purposes;
• To conduct research;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated, de-identified, and/or anonymized information. We may create aggregated, de-identified and/or anonymized information from your Personal Information and other individuals whose Personal Information we collect. We make Personal Information into de-identified and/or anonymized information by removing data that makes the information identifiable to you. We may use this aggregated, de-identified and/or anonymized information and share it with our corporate affiliates and third parties for our lawful business purposes, including to analyze the effectiveness of our Service, to conduct research, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated, de-identified and/or anonymized information like general user statistics with prospective business partners. From information collected through the Service, such as through cookies and other means described in this Privacy Policy, we may create aggregated, de-identified and/or anonymized. We may de-identify Protected Health Information and aggregate that de-identified data and use it and share it with others (including our corporate affiliates) for any lawful business purpose, including research and development of Ezra products and services. All uses and disclosures of Protected Health Information are only done if consistent with HIPAA permitted uses and disclosures.

Research. Without limitation for other purposes listed in this Privacy Policy, we may use aggregated, de-identified, and/or anonymized information for current or future research purposes, including to train our Artificial Intelligence (“AI”) and to improve our products and services. We will de-identify information only in accordance with HIPAA (as applicable), the terms of our Business Associate Agreements (as applicable), and as otherwise permitted by law.

Marketing and Other Communications. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. If you provide your telephone number, you acknowledge and agree that we may contact you, including but not limited to for promotional, informational and other purposes, using SMS text messages, cellular or telephone calls, and push notifications (if applicable) even if you have opted in to the National Do Not Call List, any state equivalent Do Not Call List or the internal Do Not Call List of any company, and that such messages and calls may be sent using automatic dialing systems or artificial or prerecorded voice messages, as detailed in the Terms. You are not required to consent to receive SMS text messages or phone calls as a condition of using the Service. If you would like to opt out of text messages or calls, you may text “STOP” from the device receiving such communications to the source number. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond o your requests. We will not use your Protected Health Information for marketing purposes, unless you provide express consent to do so.

Sharing and Disclosure of Personal Information

In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, as follows:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of the Imaging Locations that perform your scans, hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. These parties will access, process, or store Personal Information in the course of performing their duties to us pursuant to our instructions and, consistent with applicable law, appropriate contractual restrictions.
• Within Ezra: Ezra may share Personal Information among our corporate parent, subsidiaries, and/or affiliates where permitted by applicable law and pursuant to appropriate safeguards. Our corporate parent, subsidiaries, and/or affiliates may use and share such Personal Information in a manner consistent with this Privacy Policy and, where applicable, HIPAA.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
• Social Sharing: If you elect to use features that allow you to share the altered results of your Ezra scan, which may contain Personal Information, on your own pages on the Social Media Sites (“Social Sharing”), we will share the information you elect with the provider of such Social Media Sites. The Social Media Sites’ providers may use and share the information you provide in accordance with their respective privacy policies and terms of use. For additional information about Social Sharing, please see here.

Data Retention

We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, medical record retention, or other purposes), whichever is longer.

Children

Our Service is not directed to children who are under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Service please contact us and we will endeavor to delete that information from our databases.

Links To Other Websites

The Service may contain links to other websites and services not operated or controlled by us, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Social Sharing

The Social Sharing features of the Service give you the option to share the altered results of your Ezra scan on your page(s) hosted on Social Media Sites. If you elect to use Social Sharing features, we will share the information you elect with the Social Media Sites you choose. By using Social Sharing, you acknowledge and agree that the information you share with the Social Media Sites using Social Sharing may contain Personal Information, including Protected Health Information, and that your voluntary use of the Social Sharing features may remove this information from protection under HIPAA and/or other applicable laws. As with other Third Party Sites, information shared with Social Media Sites via Social Sharing governed by the specific privacy policies and terms of service of the Social Media Sites and not by this Privacy Policy.

Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

International Users

By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.

Your Choices

In certain circumstances, providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features or the Service. You can contact us by email at privacy@ezra.com if you need to update or correct your Personal Information. You may also request that we delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity and records generated prior to deletion, including transactions through the Service, will remain stored by us and may be shared with third parties as detailed in this Privacy Policy. Any information that has been aggregated, de-identified, and/or anonymized cannot be re-associated with you, therefore we will not be able to delete this type of information.

Changes To The Privacy Policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

Contact Us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us via email at privacy@ezra.com.

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