Tolu Health Privacy Policy

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Effective Date: October 7, 2025

Introduction

Hormonly Health Technologies (“Company,” “Tolu,” “we,” “our,” or “us”) values your privacy and is committed to protecting your personal and health information. This Privacy Policy explains how we collect, use, protect, and share your data when you access our mobile application, website, or affiliated platforms (collectively, the “Services”).

Tolu is currently undergoing a HIPAA Critical Controls Risk Assessment to align with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and related healthcare data protection standards. This work demonstrates our proactive commitment to building and maintaining a secure, compliant environment for all users.

Scope

This Privacy Policy applies to all users of our Services. It covers:

  • Information you provide directly to Tolu
  • Information we collect automatically through your use of our platform

This policy does not cover third-party websites, links, or external services. Their privacy practices are governed by their own policies.

Information We Collect

a. Information You Provide

  • Full name, email address, and phone number
  • Demographic details (e.g., age, gender, location)
  • Health history, lab test results, symptoms, and medications
  • Lifestyle and behavioral data (e.g., sleep, nutrition, activity)
  • Content you upload or submit (e.g., questions, notes, or audio recordings)

b. Information Collected Automatically

  • Device and browser information (IP address, OS, device type)
  • Usage and interaction data within the app
  • Cookies and similar tracking technologies

How We Use Your Information

We use your information to:

  • Deliver, personalize, and improve our Services
  • Generate AI-powered insights and educational health content
  • Facilitate practitioner or educator interactions (with your consent)
  • Enhance security, compliance, and platform functionality
  • Support audits, risk assessments, and regulatory obligations

We will never use your Protected Health Information (PHI) for advertising or marketing purposes without your explicit written authorization, in accordance with HIPAA.

Sharing Your Information

We do not sell your personal or health information. We may share limited data under these conditions:

  • With your consent: when you choose to share your data with a practitioner or educator
  • With trusted service providers: such as Amazon Web Services (AWS), which hosts our data under a HIPAA-eligible environment governed by a Business Associate Agreement (BAA)
  • With auditors or consultants: assisting in security and HIPAA readiness assessments under confidentiality obligations
  • As required by law: to comply with applicable legal or regulatory requests
  • During a business transition: such as a merger or acquisition, with equivalent safeguards maintained

HIPAA Readiness and Compliance Commitment

Tolu is currently conducting a HIPAA Critical Controls Assessment led by an external security consultant to evaluate key safeguards, including:

  • Access control and authentication
  • Encryption and transmission security
  • Audit and integrity controls
  • Risk management and contingency planning

While Tolu is not yet a covered entity or certified HIPAA-compliant organization, we are actively implementing the administrative, technical, and physical safeguards required by HIPAA’s Security Rule.

You have the right to:

  • Request access to your personal and health information
  • Request corrections or updates to inaccurate data
  • Receive a record of certain disclosures
  • Request restrictions on certain uses or disclosures
  • File a complaint with us or with the U.S. Department of Health & Human Services (HHS)

For HIPAA-related inquiries or requests, please contact:
📧 support@tolu.health
Subject line: “HIPAA-related request”

Data Security

Your information is protected using industry-standard encryption, access controls, and secure cloud hosting through AWS, a HIPAA-eligible service provider.

Tolu also undergoes regular security audits, including the current Critical Controls Risk Assessment, to identify and mitigate risks. While no system is completely immune to breaches, we continuously update our safeguards to protect your data.

Data Retention

We retain your data only as long as needed to provide the Services and fulfill legal or regulatory requirements. You may request deletion of your information, subject to HIPAA record retention rules and legitimate business needs.

Cookies & Tracking Technologies

Tolu uses cookies and related tools to improve user experience and system analytics. You can adjust your cookie preferences through your browser settings.

Children’s Privacy

Tolu’s Services are not intended for children under 13 years of age. If we discover that a child’s data has been collected, we will promptly delete it.

International Users

By using our Services from outside the United States, you consent to the transfer, processing, and storage of your information within the United States under applicable U.S. privacy laws.

Your Choices

You may:

  • Update or correct your information through your account settings
  • Opt out of non-essential communications
  • Request deletion of your account by contacting support@tolu.health

Changes to This Policy

We may update this Privacy Policy from time to time. Any material updates will be communicated via email or in-app notifications. Continued use of our Services after such changes constitutes acceptance of the revised policy.

Contact Us

If you have any questions, requests, or concerns about this Privacy Policy or our privacy practices, contact:

Hormonly Health Technologies (Tolu App)
📧 support@tolu.health
Subject Line: “Privacy Officer”

Tolu is an AI-powered assistant for women's health holistic care. It combines functional nutrition, root-cause investigation, and health coaching techniques to help you deliver personalized education to your audience.

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