Xylem Wellness Systems LLC (“we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This document outlines the types of information we may collect from you or that you may provide when you visit our website, use our services, or participate in our functional medicine programs, and our practices for collecting, using, maintaining, protecting, and disclosing that information.
1. Regulatory Framework and HIPAA Disclaimer
We operate under a cash-based functional medicine model. Because we do not bill insurance, Xylem Wellness Systems LLC does not operate as a “covered entity” under the Health Insurance Portability and Accountability Act (HIPAA).
However, we are fully committed to protecting your personal and clinical information in strict compliance with the Texas Data Privacy and Security Act (TDPSA) and applicable Texas state laws governing data privacy and medical record security.
2. Information Collection and Data Minimization
We practice strict data minimization, ensuring we only collect the information absolutely necessary to provide our services. We categorize the data we collect into two distinct groups:
Public-Facing Personal Data: Information collected via the website, marketing channels, and initial inquiries. This includes your name, email address, phone number, billing information, and standard website analytics.
Secure, Internal Clinical Data: Sensitive information collected during program onboarding and participation. This includes intake forms, health histories, lab-based tracking metrics, and wellness plans. This data is segregated from public-facing systems and managed entirely within our secure, compliant internal platforms.
3. Security Safeguards
We have implemented comprehensive technical, administrative, and physical security measures designed to secure your personal and clinical data from accidental loss and unauthorized access, use, alteration, and disclosure.
Technical Safeguards: All data transfers involving sensitive internal clinical data are encrypted. Access to clinical systems is protected by strict authentication protocols and limited to authorized personnel only.
Physical Safeguards: Any physical records are stored in secure, locked environments, and physical access to our data storage systems is strictly controlled.
4. SMS and Mobile Communications
By providing your mobile phone number, you consent to receive communications from us regarding your program, appointments, and promotional updates.
We will never share, trade, or sell your mobile phone number or SMS consent data to third parties or affiliates for marketing purposes.
You may withdraw your consent for SMS communications at any time by replying “STOP” to any message you receive from us.
5. Consumer Rights
In accordance with the Texas Data Privacy and Security Act, you maintain specific rights regarding your personal data. You have the right to:
Access: Confirm whether we are processing your personal data and access such data.
Correction: Correct inaccuracies in your personal data, taking into account the nature of the data and the purposes of the processing.
Deletion: Request the deletion of personal data provided by or obtained about you, subject to specific legal exemptions (see Data Retention below).
Portability: Obtain a copy of your personal data that you previously provided to us in a portable, readily usable format.
To exercise any of these rights, please contact us using the information provided at the end of this policy.
6. Data Retention
We retain your public-facing personal data only for as long as necessary to fulfill the purposes for which it was collected.
Clinical Data Exception: In accordance with Texas medical record regulations, all internal clinical data, client intake forms, and records of care provided must be retained for a mandatory minimum period of seven (7) years from the date of your last interaction with our services. Data deletion requests cannot override this state-mandated retention requirement for clinical records.
7. Communication and Marketing Opt-Out
You have the right to opt out of processing your personal data for the purposes of targeted advertising or the sale of personal data.
Email Marketing: You can opt out of marketing and promotional emails at any time by clicking the “unsubscribe” link at the bottom of our emails.
Essential Communications: Please note that opting out of marketing communications does not opt you out of essential administrative emails regarding your account, financial agreements, or direct program participation.
8. Changes to Our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the website homepage.
9. Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, or to exercise your consumer rights, contact us at:
Xylem Wellness Systems LLC Email: info@xwellness.health