Privacy Policy

Effective Date: January 21, 2026

1. Purpose and Scope

This Privacy Policy explains how VALKORA LLC, a Texas limited liability company, doing business as TRTBOSS (“TRTBOSS,” “we,” “us,” or “our”), collects, uses, discloses, and safeguards personal information in connection with the TRTBOSS technology platform, including websites, mobile applications, patient portals, and related services (collectively, the “Platform”).

This Privacy Policy applies only to personal information processed by TRTBOSS in its capacity as a non-clinical technology company and management services organization (MSO).

This Privacy Policy does not govern Protected Health Information (“PHI”) created, accessed, used, or maintained by licensed healthcare providers. PHI is governed by the applicable healthcare provider’s Notice of Privacy Practices and the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

2. Roles and Responsibilities

For clarity:

Platform Operator / MSO: TRTBOSS

Healthcare Providers: Independent, licensed clinicians or provider organizations

Pharmacies and Laboratories: Independent third-party entities

TRTBOSS:

Does not provide medical care

Does not practice medicine

Does not make clinical decisions

When TRTBOSS performs services for a healthcare provider that involve PHI, TRTBOSS acts solely as a Business Associate pursuant to a written Business Associate Agreement (BAA). In those circumstances, PHI handling is governed by the applicable BAA and the provider’s Notice of Privacy Practices—not this Privacy Policy.

3. Information We Collect

We collect personal information only as reasonably necessary to operate the Platform, facilitate access to healthcare services, comply with legal obligations, and protect against fraud, misuse, and security threats.

3.1 Information You Provide Directly

Identifiers (e.g., name, email address, phone number, account credentials)

Demographic information (e.g., age, date of birth)

Payment and transaction information (processed by third-party payment processors)

Communications with customer support or the Platform

We do not collect Social Security numbers or government-issued identification numbers unless strictly necessary for fraud prevention, identity verification, chargeback resolution, or legal compliance.

3.2 Information Collected Automatically

Device and browser characteristics

IP address and approximate geolocation (city/state level only)

Usage data, system logs, timestamps, and performance metrics

3.3 Health-Related Information

Health-related information submitted through the Platform for the purpose of obtaining healthcare services is collected on behalf of independent healthcare providers and may constitute PHI.

TRTBOSS:

Does not use health-related information for advertising, marketing, or behavioral profiling

Accesses PHI only as permitted under applicable BAAs

Limits PHI access to activities necessary to support Platform operations

4. Cookies, SDKs, and Tracking Technologies

TRTBOSS uses cookies, local storage, mobile identifiers, and similar technologies only for:

Platform functionality and authentication

Security and fraud prevention

System performance and reliability

Tracking Safeguards

Vendors act solely as service providers and may not use data for their own purposes

Technologies are configured to avoid transmission of health-related content, including:

Intake responses

Diagnoses or symptoms

Treatment or prescription information

Appointment or consultation status

URLs or metadata revealing health conditions

TRTBOSS does not permit third-party advertising cookies, pixels, or behavioral advertising SDKs

Users may control cookies through device or browser settings; disabling cookies may affect Platform functionality.

5. How We Use Personal Information

We use personal information for limited, legitimate business purposes, including:

Operating, maintaining, and securing the Platform

Facilitating access to healthcare services provided by independent clinicians

Processing payments and transactions

Communicating about accounts, services, and Platform updates

Detecting and preventing fraud and security incidents

Complying with legal and regulatory obligations

We do not use personal information for targeted advertising or marketing based on health-related data.

6. Disclosure of Personal Information

We may disclose personal information to:

Service providers acting on our behalf under confidentiality and security obligations

Independent healthcare providers, pharmacies, and laboratories at a user’s direction or to facilitate care

Payment processors and fraud-prevention partners

Professional advisors (legal, accounting, audit)

Government authorities when required by law

Successors or affiliates in connection with corporate transactions

TRTBOSS does not sell personal information and does not share personal information for cross-context behavioral advertising.

7. Consumer Health Data Notice

Certain U.S. state laws regulate consumer health data, including the Washington My Health My Data Act and similar statutes.

Categories of Consumer Health Data

Information regarding health services sought or scheduled

Health history and intake information submitted for care

Prescription and treatment coordination data

Purposes of Collection and Use

Facilitation of healthcare services

Platform operations, security, and fraud prevention

Legal and regulatory compliance

Sharing of Consumer Health Data

Licensed healthcare providers

Pharmacies and laboratories

Service providers supporting healthcare operations under contractual restrictions

TRTBOSS does not sell consumer health data and does not share consumer health data for targeted advertising.

Affirmative Express Consent

Where required by law:

Consumer health data is collected and shared only after obtaining affirmative, express consent

Consent for collection and consent for sharing may be obtained separately

Consent may be withdrawn at any time, subject to legal and operational limitations

8. Your Privacy Rights

Depending on your state of residence, you may have the right to:

Know what personal information we collect and use

Access, correct, or delete personal information

Opt out of the sale or sharing of personal information (where applicable)

Limit use of sensitive personal information

Submit requests through an authorized agent

Not be discriminated against for exercising privacy rights

We honor Global Privacy Control (GPC) signals where required by law.

9. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Policy, unless a longer period is required or permitted by law.

Medical records are retained by healthcare providers in accordance with applicable law and professional standards.

10. How to Exercise Your Privacy Rights

Requests may be submitted via:

📧 contact@trtboss.com

Any designated request mechanism made available on the Platform

We may verify your identity before processing a request. Authorized agents must provide proof of authorization.

Appeals

Where required by law, you may appeal a denial by contacting contact@trtboss.com.

11. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, audit logging, and vendor security reviews.

No system is completely secure, and we cannot guarantee absolute security.

12. Adults Only

The Platform is intended solely for individuals 18 years of age or older. TRTBOSS does not knowingly collect personal information from children and is not directed to children under COPPA.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted with an updated effective date. Continued use constitutes acceptance.

14. Contact Information

Privacy Officer
TRTBOSS (VALKORA LLC)
📧 contact@trtboss.com

15. Jurisdictional Limitations

The Platform is operated in the United States and intended for U.S. residents only.

16. California Privacy Rights (CPRA Notice)

This section applies only to California residents.

Categories of Personal Information

Identifiers

Personal records information

Commercial information

Internet or network activity

Approximate geolocation

Sensitive personal information (as defined by law)

Sale or Sharing

TRTBOSS does not sell personal information and does not share personal information for cross-context behavioral advertising.

California Resident Rights

California residents may request access, correction, deletion, limitation of sensitive personal information, and may designate an authorized agent.