Privacy Policy

This Privacy Policy describes how JetWell, Inc., a Delaware corporation, doing business as JetWell ("JetWell," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with our websites, applications, and related services (collectively, the "Services").

By accessing or using the Services, you acknowledge that you have read and understand this Privacy Policy. If you do not agree, do not use the Services.

1. Scope and Application

This Privacy Policy applies to personal information processed by JetWell when you:

• Visit or use the Services
• Create or manage an account
• Communicate with us (including via email, chat, SMS, or phone where enabled)
• Explore, request, or book services with third-party medical providers ("Providers") through JetWell
• Upload medical records or other files
• Request coordination, documentation, or insurance facilitation in connection with a booking

This Privacy Policy does not apply to the independent practices of:

• Providers and clinics
• Insurance carriers or administrators
• Payment processors
• Travel providers (e.g., airlines, hotels)
• Third-party websites or services linked from JetWell

Those parties process personal information under their own privacy policies.

2. Data Controller

For purposes of applicable data protection laws, including the General Data Protection Regulation ("GDPR"), JetWell, Inc., a Delaware corporation doing business as JetWell, is the data controller of personal information processed in connection with the Services.

Certain third parties (such as Providers, payment processors, and insurance carriers) act as independent data controllers with respect to personal information they process in connection with their own services.

Providers are separate controllers. A Provider that receives your case brief, your intake photos, and, once your booking is confirmed, your identity and travel details, receives them at your direction and processes them as an independent controller under its own law, its own professional obligations, and its own privacy notice. JetWell is not the Provider’s processor and the Provider is not JetWell’s; neither party is a HIPAA business associate of the other. JetWell binds each Provider by contract to use what it receives only to evaluate, quote, and deliver your case, not to use it for marketing, model training, or publication, not to pass it on, to delete it if it passes on or declines your case, and to tell JetWell within 72 hours of any unauthorized access. Beyond those contractual commitments, each party is responsible for its own compliance.

3. Information We Collect

We collect personal information through (A) information you provide, (B) information collected automatically, and (C) information received from third parties.

3.1 Information You Provide

You may provide:

• Account & contact information: name, email, phone number, mailing address
• Profile & preferences: procedure interests, goals, timing, budget ranges
• Health-adjacent information: intake responses, contraindications, or information you voluntarily choose to share
• Medical records & uploaded files: reports, images, lab results, treatment plans, invoices, or other health-related documents
• Travel & logistics information: destinations, dates, companion traveler details (if provided)
• Communications: messages, chats, emails, or support interactions
• Documentation inputs: information used to generate patient-directed documentation (e.g., Letters of Medical Necessity)
• Travel details you choose to provide in connection with a booked procedure, such as airline, flight number, travel dates and times, booking reference, and whether a companion is traveling with you
• Intake photos: for a package quote, the photos of the treatment area you take or upload (for a hair transplant, the hairline, crown, and donor area), together with your intake answers, after you give the separate consent shown at that step
• Traveler details you enter at checkout to confirm a package booking: your full name as it appears on your passport, your passport number, expiry date, and issuing country, and an optional emergency contact

Information about others. If you provide information about another person (such as a family member), you represent that you have authority to do so and that such person has been informed of this Privacy Policy where appropriate.

Accessibility Requests and Feedback. If you contact us to report an accessibility barrier, request assistance with an accessibility feature, or request information or services in an alternative accessible format, we will collect the information you provide in your request. This may include your name, contact information, a description of the barrier, the device, browser, and assistive technology you use, and any information you choose to share with us. We use this information solely to respond to your request, to provide alternative accessible access where applicable, and to identify and remediate accessibility issues on our platform. We do not use accessibility-related information for marketing or advertising. We may also route Accessibility Information Requests to Providers on your behalf, which necessarily involves sharing your request (and any identifying or contextual information you choose to include) with the relevant Provider. By using the Accessibility Information Request mechanism, you consent to JetWell sharing your request and related information with the Provider.

3.2 Information Collected Automatically

We may automatically collect:

• IP address and device identifiers
• Browser and operating system information
• Usage and interaction data
• Approximate location information
• Cookies and similar technologies used for authentication, analytics, performance, and security
• Information about your interactions with the Services, such as pages viewed, navigation paths, and feature usage, collected through cookies and similar technologies.
• Inferred location data, including your approximate geographic coordinates derived from your IP address, used to determine your nearest major airport for flight cost estimates and travel planning features

3.3 Information Received from Third Parties

We may receive information from:

• Providers: evaluations, quotes, treatment plans, records, aftercare instructions, Treatment Completion Reports (including itemized procedure details and amounts charged in connection with Deferred Settlement bookings), and other clinical or administrative documentation
• Insurance partners: information necessary to facilitate access to included coverage
• Payment processors: transaction confirmations and fraud indicators
• Security and analytics providers: device risk and abuse signals

3.4 Cookies and Tracking Technologies

JetWell uses cookies and similar technologies to operate, secure, and improve the Services. Cookies fall into the following categories:

• Necessary Cookies: Required for core functionality, including authentication, security, and session management. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with the Services, including page views, navigation patterns, and feature usage. These are only activated with your consent where required by applicable law.
• Marketing Cookies: Enable personalized content and advertising measurement. These are only activated with your consent where required by applicable law.

If you are located outside the United States, you will be presented with a cookie consent banner on your first visit that allows you to accept or reject non-essential cookies before they are activated. You may update your preferences at any time through:

• The "Cookie Settings" link in the site footer;
• The "Do Not Sell or Share My Personal Information" link in the site footer; or
• Browser-based privacy signals such as Global Privacy Control (GPC), where supported.

If you are located in the United States, non-essential cookies may be loaded by default for users located in the United States, in accordance with applicable law. You may manage cookies through your browser settings.

For more information, please see our Cookie Policy.

JetWell also recognizes Global Privacy Control (GPC) signals sent by supported browsers.

If a GPC signal is detected, JetWell will treat it as a request to opt out of the sale or sharing of personal information where required by applicable law. In such cases, advertising and marketing-related tracking technologies will be disabled automatically.

4. How We Use Personal Information

We use personal information to:

• Operate, maintain, and provide the Services
• Facilitate Provider discovery, coordination, and bookings
• Enable patient-Provider communication
• Process payments and transactions
• Verify and reconcile procedure charges and commission obligations in connection with Provider agreements
• Facilitate access to insurance coverage available for eligible procedures
• Create patient-directed documentation at your request
• Provide AI-assisted recommendations and system features
• Provide personalized flight cost estimates and travel planning information based on your inferred or confirmed location
• Coordinate your trip with your treating Provider, including scheduling and airport pickup, and send you travel-related reminders and updates based on the travel details you provide
• Improve usability, safety, and system performance
• Prevent fraud, abuse, and security incidents
• Comply with legal obligations and enforce agreements

JetWell does not use personal information to provide medical diagnosis or treatment.

5. AI-Assisted Processing and Model Improvement

JetWell uses automated and AI-assisted systems to support features of the Services. These include Doc AI, an AI-powered guided intake and clinic-matching assistant that processes your responses to generate personalized clinic recommendations. Doc AI matches your stated preferences – including procedure type, location, budget, and timeline – against clinic attributes in our database. Doc AI does not assess your health status, predict medical outcomes, or evaluate your eligibility for any procedure.

JetWell also uses automated and AI-assisted systems for other features such as summarization, organization of information, fraud prevention, and quality assurance.

Intake Photos and Automated Sizing

For a package quote, an automated model reads your intake photos and answers to produce a graft-count range for pricing (for a hair transplant, the pattern of loss and the number of grafts a package should cover). This read is a pricing and planning input only: it is not a clinical assessment, it does not determine your candidacy, and the treating Provider evaluates your case directly before any treatment decision. Your photos are processed for this purpose and shared with a Provider only when you send that Provider a request, as described in Section 9.2. You can decline the photo step and continue without a photo-based quote.

The read is performed by a general-purpose AI model hosted by a third-party AI service provider under contract with JetWell, which processes your photos and answers only to return the read and does not use them to train its models. The photo consent you tick before the photo step is your explicit consent to this processing (GDPR Article 9(2)(a) and, where they apply, the US state health privacy laws in Section 13.6); it is recorded with the text you read and its version, and you may withdraw it in your account settings. The read produces no legal or similarly significant effect on you within the meaning of GDPR Article 22: it sets a price range, a Provider decides on treatment, and you may ask for a human review of the read at any time by writing to privacy@jetwell.ai.

Your Dentist's Treatment Plan

If you add a treatment plan from your own dentist at intake and ask us to read it, an automated model reads the plan only to find the treatments it proposes and tick them in the intake for you to check. The read is performed by a general-purpose AI model hosted by a third-party AI service provider under contract with JetWell, which processes the plan only to return those treatments and does not use it to train its models. The model does not read X-rays or pictures of your teeth, does not assess your health and gives no medical advice: what it finds is a starting point you confirm or change, and the clinic that accepts your case checks the plan itself. The consent shown beside the button is your explicit consent to this processing (GDPR Article 9(2)(a) and, where they apply, the US state health privacy laws in Section 13.6); it is recorded with the text you read and its version, and you may withdraw it in your account settings.

Checking the Pictures You Add

When you add a picture as a record, such as an X-ray, a dentist's plan or a picture of your teeth, an automated model checks it once, as it is added, only for whether it is blurred, too dark or bright, cut off, not the kind of picture asked for, or shows a readable name or date of birth, so you can retake it before a clinic sees it. It is performed by a general-purpose AI model hosted by a third-party AI service provider under contract with JetWell, which processes the picture only to return those answers and does not use it to train its models. The check never reads the picture medically, and the picture is kept whatever it finds. The records consent you give before your first upload covers this check and says so.

Use of De-Identified Information

JetWell may use de-identified, anonymized, and aggregated information derived from user interactions, uploaded materials, and system usage to improve the accuracy, safety, reliability, and effectiveness of the Services.

This may include de-identified excerpts, metadata, or patterns derived from intake responses or uploaded files. JetWell does not use identifiable personal information to train public or third-party AI models and applies reasonable safeguards to minimize re-identification risk.

Where required by law or where offered, users may request to opt out of certain uses for system improvement without affecting core Services.

Third-Party AI Assistants (Model Context Protocol)

JetWell publishes a Model Context Protocol (MCP) server that lets third-party AI assistants (for example, ChatGPT, Claude, or a comparable client) query JetWell's public catalog on your behalf. When you reach JetWell through one of these assistants, your query first passes through that assistant's systems under that assistant's privacy policy before any information is sent to JetWell.

The MCP tools receive only structured search parameters and a short procedure term (capped at 120 characters), together with the qualification answers you provide during the handoff conversation (procedure specifics, timeline, and destination preference). No health information, no date of birth, and no email or phone number is collected through the AI assistant. Date of birth, health screening, and contact details are collected only on jetwell.ai, under this policy and JetWell's consent flow, after you land on the site.

JetWell logs each MCP tool call (tool name, timestamp, client name, structured inputs, response size, and outcome) in an internal mcp_tool_calls record for security monitoring, rate-limit enforcement, and quality review. These records are retained for up to 12 months and are not shared with third parties. Qualification sessions (mcp_sessions) expire 7 days after creation and are deleted or de-identified thereafter unless linked to a JetWell account you have created.

To exercise your privacy rights or to request deletion of MCP session records, contact JetWell at privacy@jetwell.ai.

6. Patient-Directed Documentation

At your request, JetWell may assist in organizing, summarizing, formatting, or generating documentation using information you provide and/or information received from Providers (for example, a Letter of Medical Necessity).

• Documentation is prepared at your direction and provided to you
• JetWell does not submit documentation to insurers, HSA administrators, employers, or government agencies on your behalf
• JetWell does not guarantee reimbursement, eligibility, tax treatment, or acceptance of any documentation

7. Medical Records and Provider Uploads

7.1 Medical Records Uploaded by Users

The Services may allow you to upload medical records or health-related files for Provider evaluation, coordination, or documentation purposes.

7.2 Medical Records Uploaded by Providers

JetWell may allow Providers to upload medical records, reports, images, treatment summaries, invoices, aftercare instructions, or other health-related documentation to your account for your ownership and use.

Such records are uploaded by Providers on behalf of the patient. JetWell acts solely as a secure custodian of this information and does not originate or control Provider medical records or clinical documentation.

Access is limited to the patient, authorized personnel, and service providers acting under confidentiality obligations, unless the patient directs otherwise.

8. Data Retention

JetWell retains personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Medical records and health-related files (whether uploaded by users or Providers) are retained for a default period of seven (7) years following booking completion or last account activity, unless a longer period is required by law, necessary to resolve disputes, or requested by the patient.
• Account and profile information is retained for the duration of your account and for three (3) years following account closure or last activity.
• Intake photos taken for a package quote are deleted ninety (90) days after upload unless you send a request to a Provider. If that request ends without a booking, they are deleted within thirty (30) days after it ends, and not sooner than ninety (90) days after upload. If you book, they are kept with your medical records for seven (7) years after the booking is completed or canceled, to provide the Services, resolve disputes, and meet legal and audit obligations. A Provider that receives your photos may use them only to evaluate your case and must delete them if it declines or passes on it. Records you send a Provider that asks to see them before your deposit, such as an X-ray, a scan report, your own dentist's plan or pictures of your teeth, are kept and deleted under the same rule. So are records you choose to add during the intake, such as your dentist's treatment plan or an X-ray: no Provider sees them until it accepts your case, and only the Provider that accepts it receives a copy.
• Passport details entered at checkout are shown to you in masked form, shared with your Provider when your booking is confirmed and with the underwriter where required for coverage, and kept for as long as your coverage and any claim under it may require and as the law requires. You can ask us to delete them once your trip and any claim are completed, unless the law requires us to keep them.
• Case and transaction records are retained for seven (7) years following completion to satisfy financial, tax, and legal retention obligations.
• Communications and messages are retained for two (2) years following case completion.
• Analytics and usage data is retained for one (1) year and then anonymized or deleted.
• Consent records and audit logs are retained for seven (7) years as proof of lawful processing and regulatory compliance, even if you request account deletion.

Patients may request earlier deletion of personal information, subject to JetWell's legal, regulatory, and operational obligations. Upon expiration of the applicable retention period, information is securely deleted or irreversibly de-identified.

JetWell may retain de-identified or anonymized data indefinitely for system improvement, analytics, security, or compliance purposes.

9. How We Share Personal Information

JetWell does not sell personal information for monetary compensation.

We do not use personal information for cross-context behavioral advertising as part of our core Services. However, certain uses of cookies or similar technologies for analytics or measurement purposes may be considered “sharing” under California law.

Where required, JetWell provides users with the ability to opt out of such processing.

9.1 Service Providers

With vendors who perform services on our behalf (e.g., hosting, analytics, communications, security, customer support, and AI infrastructure). Where AI-powered features of the Services rely on third-party AI model providers for processing, your inputs may be transmitted to such providers solely for the purpose of generating outputs within the Services. These providers are contractually required to protect information and use it only for authorized purposes.

JetWell may also use third-party data services to obtain aggregated, non-personalized flight pricing data for the purpose of displaying estimated fare ranges on the Services. These services receive route and date parameters only and do not receive any personal information, health information, or user identifiers from JetWell.

JetWell may also use third-party flight data services to resolve and monitor flight information you provide, such as retrieving route and schedule details from an airline and flight number. These services receive flight identifiers and dates only and do not receive your name, contact information, health information, or any other personal identifiers from JetWell.

9.2 Providers and Clinics (At Your Direction)

With Providers to facilitate evaluations, coordination, scheduling, and bookings, including sharing medical records or health-adjacent information you choose to provide.

Package requests. When you send a package request, the Providers JetWell routes it to receive a case brief: your procedure, your intake answers and photos, the graft-count range, your package choices, and your travel window, identified by your first name and last initial only. Your full name, contact details, and passport details are not shared with a Provider until your deposit is captured and your booking is confirmed, and the Provider is not named to you until then either. Messages you exchange with a Provider before confirmation pass through the Services and are screened to remove contact details and identifying information; a message that is altered by the screen is logged so that we can review how the screen performed.

Providers may also share information with JetWell in connection with your booking, including treatment details, procedure charges, and completion reports necessary for commission reconciliation and quality assurance. JetWell treats such information as confidential and uses it solely for Platform purposes as described in this Privacy Policy.

If you provide travel details in connection with a booked procedure, we share those details with your treating Provider and its authorized coordinators so they can coordinate your care and trip logistics, such as confirming your arrival, scheduling appointments, and arranging airport pickup where offered.

9.3 Insurance Partners

With insurance partners and insurers, as necessary to facilitate access to insurance coverage available for eligible procedures. Insurance partners process information under their own privacy practices and policy terms.

9.4 Payment Processors

With payment processors to complete transactions, prevent fraud, handle chargebacks, and provide receipts.

9.5 Legal and Safety Purposes

When we believe in good faith that disclosure is necessary to comply with law, protect rights or safety, prevent fraud or abuse, or enforce agreements.

9.6 Business Transfers

In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality protections.

10. HIPAA-Compliant Safeguards

JetWell is not a "covered entity" or "business associate" under the Health Insurance Portability and Accountability Act ("HIPAA"). However, JetWell voluntarily maintains administrative, physical, and technical safeguards that comply with HIPAA security standards and healthcare privacy best practices. These safeguards include documented security and privacy policies, a formal Security Risk Assessment, workforce security training, role-based access controls, encrypted data storage and transmission, comprehensive audit logging with six-year retention, and a documented breach notification plan. JetWell may apply these safeguards globally where appropriate.

Any security assessments or certifications JetWell may pursue do not create additional warranties beyond those described in this Privacy Policy.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information. No system is completely secure, and we cannot guarantee absolute security.

If a data incident occurs, we will provide notice as required by applicable law.

12. International Data Transfers

JetWell is based in the United States. If you are located outside the United States, your personal information may be transferred to and processed in the United States or other jurisdictions where JetWell or its service providers operate.

Where required by applicable law, JetWell relies on appropriate safeguards to support lawful international data transfers, such as Standard Contractual Clauses approved by the European Commission or other recognized transfer mechanisms.

The following categories of recipients may process personal data outside the EEA:

• JetWell (United States): Primary data processing. Safeguard: Standard Contractual Clauses.
• Service providers (various jurisdictions): Hosting, analytics, communications. Safeguard: Standard Contractual Clauses or equivalent mechanisms.
• Providers (various jurisdictions): Case evaluation, quoting, care coordination, and treatment, in the destination country you chose. Your case brief and intake photos are transferred to the Provider when you send a request, and your identity and travel details when your booking is confirmed. Safeguard: your explicit consent to the transfer, given with the photo consent and the request, after being told that the destination country may not provide protections equivalent to your own (GDPR Article 49(1)(a)), and, where JetWell has one in place with the Provider, the controller to controller module of the Standard Contractual Clauses; plus the contractual commitments in Section 2.
• Insurance partners: Coverage facilitation. Safeguard: Standard Contractual Clauses or contractual protections.
• Payment processors: Transaction processing. Safeguard: Standard Contractual Clauses; PCI DSS compliance.

13. Additional Information for EU, UK, and EEA Users

If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, the following additional information applies.

13.1 Legal Bases for Processing

JetWell processes personal information only where permitted by applicable law, including where processing is:

• Necessary to perform a contract with you or to take steps at your request prior to entering into a contract
• Based on your consent, where required
• Necessary for JetWell's legitimate interests, such as operating, securing, and improving the Services, provided those interests are not overridden by your rights
• Required to comply with legal obligations

13.2 Special Category Data

Certain information you choose to provide through the Services, including health-related information shared during the intake process or uploaded as medical records, may constitute "special category data" under GDPR.

Before collecting health-related information, JetWell will request your explicit consent through a clear, separate consent mechanism. This consent is distinct from any cookie or marketing consent and may be withdrawn at any time without affecting the lawfulness of processing performed before withdrawal. For a package quote there are three such consents, each recorded with its text and version: the health questions in the intake, the intake photos and their automated read (Section 5), and the sharing of your case with the Provider that reviews your request (Section 9.2). Withdrawing the sharing consent while a request is open withdraws the request.

JetWell processes health-related information only for the purposes you have consented to, including care coordination, clinic matching, documentation, and related Services. JetWell does not use health-related information for advertising purposes and does not sell such information.

13.3 Data Subject Rights

Subject to applicable law, you have the right to:

• Access your personal data
• Correct inaccurate or incomplete data
• Request deletion of your personal data
• Restrict or object to certain processing
• Request data portability
• Withdraw consent where processing is based on consent

You may exercise these rights by contacting us using the details in the "Contact Us" section. We may need to verify your identity before responding.

JetWell will respond to verified data subject requests within thirty (30) days of receipt. If a request is complex or we receive a high volume of requests, we may extend this period by an additional sixty (60) days, in which case we will notify you of the extension and the reasons for it within the initial thirty-day period.

You may submit requests through the "Your Data Rights" section of your account settings or by contacting us at privacy@jetwell.ai.

13.4 Supervisory Authority

You also have the right to lodge a complaint with a data protection supervisory authority in your country of residence, place of work, or where an alleged infringement occurred.

13.5 Automated Decision-Making

JetWell uses automated systems, including AI-assisted tools such as Doc AI, to provide features including clinic recommendations, intake processing, cost information, and fraud prevention. These systems support and inform your decisions but do not produce legal effects or similarly significant effects on you. No automated system restricts your access to the Services or determines your eligibility for any procedure or service. All clinic recommendations are informational, and you are free to disregard any recommendation and contact any JetWell Certified clinic directly.

In accordance with applicable law, including the EU AI Act (Regulation (EU) 2024/1689) and GDPR Article 22, JetWell discloses that its AI-powered features, including Doc AI, are automated systems. You have the right to request human review of any recommendation or decision made with the assistance of automated systems. You may exercise this right by contacting us at privacy@jetwell.ai. The automated sizing read described in Section 5 is one such system: it informs a price range and nothing else, and a Provider, not the read, decides whether and how you are treated.

13.6 Where JetWell Offers the Services; Representative

JetWell is established in the United States and currently offers bookings to patients resident in the United States. JetWell does not at present direct the Services to individuals in the EEA, the United Kingdom or Switzerland, and has not appointed a representative under Article 27 of the GDPR or Article 27 of the UK GDPR. Before JetWell offers bookings to patients in the EEA or the United Kingdom it will appoint a representative established there, name that representative and their contact details in this Section, and, where required, register with the relevant supervisory authority. Until then, requests and complaints from individuals in those regions are handled by JetWell directly at privacy@jetwell.ai, and the rights in Section 13.3 apply to any personal data JetWell holds about you.

13.7 Transfers From the EEA, the United Kingdom and Switzerland

JetWell operates from the United States, and the Providers you may book with are located outside the EEA and the United Kingdom. If you use the Services from one of those regions, your personal data, including health information, is transferred to the United States and to the country of the Provider you choose. JetWell's own processing in the United States is covered by the Standard Contractual Clauses and the UK Addendum with its service providers. The transfer of your case to a Provider is made at your request and with your explicit consent to that transfer (Article 49(1)(a) of the GDPR and the UK GDPR), which JetWell records with the text you saw; JetWell's Participation Agreement also binds each Provider to the controller-to-controller Standard Contractual Clauses and the UK Addendum for that data. You may withdraw the sharing consent at any time as described in Section 13.2.

13.8 Assessments

JetWell maintains a data protection impact assessment for the automated photo read described in Section 5 and for the sharing of health information with Providers, reviews it before any change to those features, and will make a summary available to a supervisory authority on request.

13.9 US State Health Privacy Laws

In addition to GDPR's special category data protections, JetWell complies with applicable US state health data privacy laws, including Washington's My Health My Data Act (RCW 19.373), Nevada's SB 370 (NRS 603A.400), and Connecticut's health data privacy law (Public Act 23-56). These laws apply to "consumer health data" collected by entities that are not regulated under HIPAA. Where these laws apply, JetWell will obtain your specific affirmative consent before collecting health-related information, will not sell consumer health data, and will honor your rights to access, delete, and withdraw consent for the processing of your health data. These rights are in addition to, not in place of, any other rights described in this Privacy Policy.

14. Your Rights and Choices

Your rights may vary depending on your location and applicable law.

Depending on your location, you may have rights to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of certain personal information
• Request portability where applicable
• Object to or restrict certain processing
• Opt out of certain communications

To exercise your rights, contact us as described below. We may need to verify your identity before responding, and some rights may be subject to limitations or exceptions under applicable law.

You may also manage certain data processing preferences, including cookies and similar technologies, through controls available on the Services, including “Cookie Settings” and “Do Not Sell or Share My Personal Information,” or by using browser-based privacy signals such as Global Privacy Control (GPC).

15. Children's Privacy

The Services are intended for individuals 18 years of age or older. JetWell does not knowingly allow individuals under 18 to create accounts or interact directly with the Services on their own behalf.

A parent or legal guardian may use JetWell to coordinate care for a dependent under 18. In that case, the guardian's account is the account of record, and the guardian is responsible for any personal or health information they provide about the dependent. JetWell processes such information solely to facilitate the requested care and related services, in accordance with this Privacy Policy and applicable law. Additional verification and documentation may be required before a minor's case can proceed.

If we become aware that a person under 18 has created an account or submitted personal information to the Services without the involvement of a parent or legal guardian, we will take steps to delete that information. Parents or guardians who believe a minor has provided information to JetWell without their authorization may contact us using the details below.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last Updated" date and, where required by law, provide additional notice of material changes.

17. Contact Us

JetWell, Inc.
d/b/a JetWell
6543 S Las Vegas Blvd
Las Vegas, NV 89119
Email: privacy@jetwell.ai

Appendix A: California Privacy Notice (CCPA / CPRA)

This Appendix applies if you are a California resident and supplements the Privacy Policy above.

Right to Opt Out of Sale or Sharing

If you are a California resident, you have the right to opt out of the “sale” or “sharing” of your personal information, as those terms are defined under California law.

JetWell does not sell personal information for monetary compensation. However, certain uses of cookies or similar technologies for analytics or advertising purposes may be considered “sharing” under California law.

How to Exercise Your Right to Opt Out

You may exercise your right to opt out of such sale or sharing by:

• Clicking the “Do Not Sell or Share My Personal Information” link available in the website footer; or
• Enabling a Global Privacy Control (GPC) signal in your browser.

Global Privacy Control (GPC)

JetWell recognizes and honors Global Privacy Control (GPC) signals sent by your browser.

If your browser transmits a GPC signal, we will treat it as a valid request to opt out of the sale or sharing of your personal information where required by applicable law.

When a GPC signal is detected:

• Advertising and marketing-related tracking technologies are disabled;
• Data processing for cross-context behavioral advertising is limited; and
• Your opt-out preference is applied automatically without requiring further action.

A1. Categories of Personal Information Collected

• Identifiers (name, contact info, IP address)
• Customer records (billing address, transaction confirmations)
• Commercial information (booking history)
• Internet or network activity (usage, device data)
• Geolocation data (approximate; precise only if enabled)
• Sensitive personal information (health-adjacent data you choose to provide; government ID if provided for travel or verification)

Retention periods for each category are described in Section 8 of the main Privacy Policy.

A2. Purposes of Use

As described in Section 4.

A3. Categories of Third Parties

Service providers, Providers/clinics, insurance partners/insurers, payment processors, legal authorities.

A4. Sale or Sharing

JetWell does not sell personal information for monetary compensation.

JetWell does not engage in cross-context behavioral advertising as part of its core Services. However, certain uses of cookies or similar technologies for analytics or measurement purposes may be considered “sharing” under California law.

Where required, JetWell provides users with the ability to opt out of such processing.

A5. Limiting Use of Sensitive Personal Information

JetWell uses sensitive personal information only as reasonably necessary to provide the Services, ensure security, prevent fraud, and comply with law.

A6. Exercising Rights

Contact privacy@jetwell.ai with the subject line "California Privacy Request." JetWell will not discriminate against you for exercising your rights.

Appendix B: EU / UK Privacy Notice (GDPR)

This Appendix applies to individuals located in the European Economic Area, the United Kingdom, or Switzerland and supplements the Privacy Policy above.

Data Controller. JetWell processes personal data as an independent data controller. Providers, insurers, and payment processors act as independent data controllers for data they process in connection with their own services. JetWell does not act as a data processor on behalf of Providers unless expressly agreed in writing.

Legal Bases. JetWell's legal bases for processing are described in Section 13.1 of this Privacy Policy.

International Transfers. Your personal data may be transferred to the United States and other countries where JetWell, its service providers, or Providers operate. Where such transfers occur, JetWell relies on Standard Contractual Clauses approved by the European Commission, or other recognized transfer mechanisms, to ensure appropriate safeguards are in place. Transfers to Providers in connection with your bookings are made at your direction and with your explicit consent.

Data Subject Rights. Your rights under GDPR are described in Section 13.3 of this Privacy Policy. You may exercise these rights through your account settings or by contacting privacy@jetwell.ai.

Supervisory Authority. You have the right to lodge a complaint with a data protection supervisory authority in your country of residence, place of work, or where an alleged infringement occurred.

Cookie Consent. If you are located in the EEA, UK, or Switzerland, non-essential cookies will not be activated until you provide consent through our cookie consent banner. You may change your preferences at any time via the "Cookie Settings" link in the site footer.