Effective Date: May 3, 2025
Last Updated: May 3, 2025
Applies to: Qwitly (“Qwitly,” “we,” “us,” “our”) including the qwitly.com website, mobile experiences, tele‑medical platform, and related services.
We collect only the information we need to prescribe evidence‑based smoking‑cessation treatment, ship medication, bill for services, and improve our program. We never sell or rent your data, and we share it only with partners who help us deliver care—pharmacies, payment processors, analytics providers bound by strict contracts, or when the law requires it. You have rights to know, access, correct, delete, or limit use of your information, and exercising those rights will never affect the quality of care you receive.
This Policy covers all visitors to qwitly.com and all patients who use our telemedicine service in the United States. Separate regional addenda describe additional rights for residents of California, Virginia, Colorado, Connecticut, and Utah, and a GDPR notice applies to incidental EEA/UK visitors.
Information you provide when you create an account, complete the online assessment, communicate with clinicians, or upload documents: name, date of birth, mailing address, phone, email, medical history, smoking history, and payment details.
Information we generate such as treatment plans, prescriptions, progress notes, and clinical metrics.
Information we collect automatically: device type, browser, IP address, pages visited, time on site, and diagnostic logs. We use first‑party cookies for site functionality and third‑party analytics cookies (Google Analytics, Hotjar) to understand usage. See Section 11 for details.
Information from third parties: identity verification vendors, pharmacies, insurers, and payment processors.
For individuals located in the European Economic Area or the United Kingdom who reach our site incidentally, we process personal data on the bases of legitimate interest (running a secure medical platform), contract (providing requested services), and legal obligation (medical record retention). Where required we rely on your explicit consent—for example, before setting non‑essential cookies.
We disclose personal information only:
You may request access to, correction of, or deletion of your medical record; obtain an accounting of disclosures; request restrictions on certain uses; or receive information by alternate means. See HIPAA Notice of Privacy Practices (Appendix A) for procedures.
Residents of these states have the right to know, correct, delete, and opt out of sale/share of personal information. We honor Global Privacy Control (GPC) signals. To exercise any right, email privacy@qwitly.com or visit our Data Choices page in the footer. We will verify your identity and respond within 45 days.
EEA/UK visitors may have the right to access, rectify, erase, restrict, or port personal data, and to object to processing. Contact privacy@qwitly.com. Qwitly’s lead supervisory authority is the Irish Data Protection Commission.
Our services are intended for adults 18 years and older. We do not knowingly collect information from children under 13. If we learn that we have inadvertently collected such information, we will delete it.
We follow industry standards to protect information, including encryption at rest and in transit (TLS 1.3), role‑based access controls, annual penetration testing, and HIPAA‑compliant cloud hosting. No method of transmission is 100 % secure; we encourage you to use unique passwords and enable multi‑factor authentication.
We use:
Data is stored and processed in the United States. For EU/UK visitors we rely on Standard Contractual Clauses and HIPAA‑level security measures to protect data transferred across borders.
We may update this Policy to reflect changes in law or our practices. If changes are material we will post a prominent notice and email account holders. The “Last Updated” date at the top shows when the latest changes took effect.
Qwitly — Brain Metrics Lab, dba Safa Rubaye LLC
Attn: Privacy Officer
7800 I‑10, Suite I 624
San Antonio, TX 78230, USA
Phone: +1 (210) 555‑0123
Email: privacy@qwitly.com
This Notice explains how we may use and disclose your Protected Health Information (PHI) and your rights under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
We are required to maintain the privacy of PHI, provide this Notice, and follow its terms. We will notify you if a breach compromises your PHI.
You may:
Submit written requests to the Privacy Officer at the address above or email hipaa@qwitly.com. We will respond within 30 days.
If you believe your privacy rights have been violated, contact our Privacy Officer. You may also file a complaint with the U.S. Department of Health and Human Services’ Office for Civil Rights. We will not retaliate for complaints.
Residents of these states may exercise additional rights described in Section 7.2. To make a request, call +1 (210) 555‑0123, email privacy@qwitly.com, or click “Do Not Sell/Share My Info” in our footer. Authorized agents must provide written permission and may be required to verify identity.
If we deny your request you may appeal by emailing privacyappeal@qwitly.com. We will respond within 60 days.