ENAVVI, INC.

PRIVACY POLICY

Effective Date:August 14, 2026

This Privacy Policy describes how enavvi collects, uses, and shares personal information in connection with the Services. Where enavvi processes information on behalf of a customer under a written contract (including a Business Associate Agreement), that contract governs such processing. This Policy does not apply to third-party services not owned or controlled by enavvi.

INFORMATION WE COLLECT

We collect information when you use the Services, create or administer an account, or otherwise interact with enavvi. Categories include:

  • Account and profile information: name, email, username, role, organization, and related account details.
  • Provider and professional information: credentials, NPI, DEA registration, specialty, practice location, and prescribing authority.
  • Patient and clinical information: patient identifiers, demographic data, medication history, prescription information, and other health-related data submitted by customers, providers, or integrated systems.
  • Prescription and transaction information: prescription details, dosage, pharmacy routing, transaction timestamps, and related records.
  • Identity verification and onboarding information: information submitted during registration, credentialing, or identity proofing, including from third-party verification providers.
  • Communications and support information: messages, support tickets, feedback, and related communications.
  • Device, log, and usage information: IP address, browser type, pages viewed, session data, and diagnostic information.
  • Integration and third-party source information: information received from EHR systems, pharmacy networks, and other integrated services.
  • Billing and business contact information: payment records, subscription details, and customer contact information.

We may also collect aggregated or de-identified information that does not identify individuals.

HOW WE USE INFORMATION

We use collected information to:

  • Provide, operate, and support the Services, including account access, prescribing workflows, and integrations.
  • Authenticate users, manage access controls, and maintain security and service integrity.
  • Process transactions and route prescriptions to pharmacies and other recipients.
  • Respond to support requests, troubleshoot issues, and communicate about service matters.
  • Comply with legal, regulatory, audit, and recordkeeping obligations.
  • Analyze performance and improve the Services. We may use aggregated or de-identified information for analytics and product development.
  • Manage customer accounts, billing, and contracting.

HOW WE SHARE INFORMATION

We share information only as necessary to provide the Services or as required by law. Recipients may include:

  • Customers and authorized organizations: the customer or practice that administers your access, for account management and workflow purposes.
  • Pharmacies and prescribing-related recipients: prescription, provider, and routing information shared with pharmacies and pharmacy networks as part of prescription processing.
  • Service providers and vendors: hosting, analytics, support, identity verification, and other vendors acting on our behalf, subject to confidentiality obligations.
  • Integrated systems: EHR systems, payment processors, and other third-party services authorized by the applicable customer.
  • Legal and regulatory recipients: governmental authorities, courts, or law enforcement when required or permitted by law.
  • Corporate transaction participants: in connection with a merger, acquisition, or sale of assets, subject to appropriate protections.
  • At your or your customer's direction: when authorized through the Services or an applicable agreement.

We do not sell personal information. We may share aggregated or de-identified information for analytics and reporting.

COOKIES AND TRACKING TECHNOLOGIES

We and our service providers may use cookies, web beacons, and similar technologies to operate and improve the Services, maintain sessions, diagnose performance issues, and support internal analytics. You may manage certain cookies through your browser settings; disabling cookies may affect Service functionality.

DATA RETENTION AND SECURITY

We retain personal information for as long as necessary to provide the Services, comply with legal and regulatory obligations, resolve disputes, and conduct legitimate business operations. EPCS audit logs are retained for a minimum of two years from the date of the logged event, consistent with 21 CFR § 1311.305. For other information, retention periods vary based on the type of information and applicable requirements.

Our security safeguards are described in Section 3 of the applicable Service Subscription Agreement between eNavvi and Customer. No electronic system is completely secure, and security also depends on appropriate customer and user practices.

YOUR CHOICES AND RIGHTS

Depending on your relationship with enavvi and applicable law, you may have rights to access, update, correct, or request deletion of certain personal information. If you access the Services through a healthcare provider or employer, that organization may control certain information and be responsible for handling privacy requests. You may opt out of marketing communications using the unsubscribe mechanism in those communications.

We may decline or limit requests where permitted by law, where we cannot verify identity or authority, or where retention is required for legal, regulatory, audit, or dispute-resolution purposes.

SMS / TEXT MESSAGING

If you provide a mobile phone number and consent to receive text messages from enavvi, we collect your mobile number, your consent record (date, time, and how consent was given), and message delivery information, and we use them solely to send the messages you opted into: account-security one-time passcodes (login verification, EPCS two-factor authentication, and password reset) and prescription and patient-wallet notifications for your practice. Message frequency varies based on your account and prescribing activity. Message and data rates may apply.

You can opt out of text messages at any time by replying STOP to any message, and you can get help by replying HELP or by contacting help@enavvi.com. Providing a mobile number is optional and is not a condition of creating or using an account.

Mobile opt-in data and SMS consent will not be shared, rented, transferred, or sold to third parties, affiliates, or lead generators for marketing or promotional purposes.

CHILDREN'S PRIVACY

The Services are intended for healthcare providers, prescribers, and authorized users in professional contexts. Information about minors may be processed when submitted by customers or providers in clinical workflows; in those cases, the applicable customer or provider is responsible for obtaining required permissions and complying with applicable law.

POLICY UPDATES AND CONTACT

We may update this Policy to reflect changes in our Services, practices, or legal obligations. Material changes will be communicated via the Services, email, or other reasonable means. Continued use after the updated Policy takes effect constitutes acceptance, subject to rights that cannot be waived by law.

Questions or privacy requests:

ENAVVI, INC.

Attn: eNavvi Security and Compliance Team

21 Esfahan Dr

San Jose, CA 95111

Email: teja@enavvi.com