PRIVACY NOTICE

Last Updated: August 24, 2026

Sana Skin, Inc. helps make the Goeckerman therapy - an effective, safe therapy for eczema and psoriasis - accessible to you at home. We use the information you share with us to help provide you with a customized experience throughout your treatment journey.

Sana Skin, Inc., our fully owned and operated brands, and our provider and related entities (“Sana Skin,”, “Solay”, “we,” “us,” or “our”) take your privacy and trust in us seriously. We are committed to protecting the privacy and security of the information that you share with us.

The purpose of this Privacy Notice is to explain how we may collect, use, store, disclose, or otherwise process your personal information when you interact with us through our website located at https://solayhealth.com, our products and services, and/or other communication channels under our control such as email, telephone, or social media that link to this Privacy Notice (collectively, “Services” or “Website”).

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. All capitalized terms not otherwise defined in this Privacy Notice have the same meaning as set forth in the Sana Skin Terms of Service.

If you have questions or concerns about this Privacy Notice, please contact shawn.thomas@solayhealth.com.

1. Collection of Information

Sana Skin collects and stores a variety of information when you use our Services so that we can provide the Services to you. If we do not have this information, you may not be able to access or use part or all of our Services. The specific types of information we collect will depend on the Services you use, but may include the following:

Personal Information

Personal information means information associated with or used to identify or contact a specific person. Personal information we collect may include:

  • Identifiers such as your first and last name, date of birth, sex or gender, physical address, email address, phone number, identification numbers, etc.

  • Audio, visual, and other electronic information such as photographs and videos for purposes other than diagnosis or treatment

  • Commercial information such as your order history, products purchased or considered, payment information, and shipping history

  • Internet and network activity information such as IP address, geolocation information, device information, log data, and cookies and similar technologies

  • Inferences drawn from any of the information collected about you such as your preferences, characteristics, and behavior, etc.

Health Information

Health information is a type of personal information that includes any identifying information we collect relating to your medical history, including symptoms, diagnoses, treatment and outcomes. Health information we collect may include:

  • Audio, visual, and other electronic information such as photographs and videos for purposes of diagnosis or treatment

  • Medical history such as medical conditions, medications, allergies, treatment options, prescriptions, and any other health-related information for purposes of diagnosis or treatment.

  • Commercial information such as your order and shipping history

2. Sources of Information

We collect information about you from the following categories of sources:

You (Actively)

You may actively provide us information when you use our Services such as through our websites, emails, social media, surveys, sweepstakes and promotions, customer support, or any other online or offline interactions.

You (Passively)

You may also passively provide us information through your interactions and use of our Services such as your IP address, access times, hardware and software information, device information, device event information (e.g., crashes, unsuccessful logins, browser type), the web page you’ve viewed or engaged with before or after using the Services, and other relevant information. We may use cookies and other tracking technology to collect this information. For more information on the cookies and other tracking technology we use, please see the Cookie section below.

Third Parties

We may receive information from third parties such as affiliates, business partners, and service providers to operate our business and improve your experience and interactions with us.

Publicly Available Databases

We may receive information that is available publicly, either online or offline, to operate our business and improve your experience and interactions with us.

3. Use of Information

Sana Skin and our service providers may use information about you to:

  • Provide teledermatology and related services;

  • Verify your identity as the holder of an account with us;

  • Administer your account, process payments, troubleshoot issues, and provide you with customer support;

  • Communicate with you about the Services, and to deliver any administrative notices or alerts and communications relevant to your use of the Services;

  • Allow you to participate in sweepstakes, contests, or other promotions;

  • Market our services and those of third parties that we believe may be of interest;

  • Tailor the features, performance and support of the Services to you and your preferences;

  • Provide, operate, analyze usage of, and improve the Services, including performing product research and development;

  • Investigate, detect, deter, prevent, report, defend against, or take other action regarding security incidents, abusive behavior, suspected fraud, malicious or illegal activities, or violations of our Terms of Service or other policies;

  • Make sure our terms, policies, and agreements with you and any third parties are enforced;

  • Comply with applicable laws and regulations.

4. Sharing of Information

We understand the importance of protecting the confidentiality of your information and limit our disclosure of your personal and/or health information to the following possible scenarios:

  • To licensed medical providers (including those who provide healthcare services, drugs, or medical devices) so that they may provide you with the teledermatology and related products and services you request;

  • To third-party service providers acting on our behalf or to entities with whom we may collaborate with to offer and deliver the Services;

  • In order to protect the safety and security of Sana Skin, the Services, our operations, our systems, our properties, our customers, or any other related person or entity;

  • In order to investigate, detect, deter, prevent, report, defend against, or take other action regarding security incidents, abusive behavior, suspected fraud, malicious or illegal activities, or violations of our Terms of Service or other policies;

  • In order to establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;

  • In order to comply with applicable laws or legal processes such as a court order or subpoena;

  • In connection with any reorganization, restructuring, merger, sale, acquisition, financing, dissolution, or other transfer of assets under the condition that the recipient agrees to respect your information in a manner that is consistent with this Privacy Notice.

5. Cookies and Other Tracking Technology

We use cookies and other tracking technologies to collect information about your use of our Services. Cookies are small files, typically composed of letters and numbers, that your computer or mobile device saves when you visit certain websites. When you return to the websites that save cookies on your device—or visit other websites that use the same cookies—the websites recognize such cookies and your browsing device.

Generally, we use first-party cookies and similar technologies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect information about your use of our Services to help us improve and optimize our Services; and to remember your preferences for your convenience.

We use the following types of cookies on our Services:

  • Strictly Necessary Cookies, which are needed for the Site or Services to operate as reasonably expected by you.

  • Functional or Preference Cookies, which remember your name or choices.

We do not use advertising or targeting cookies. We do not use cookies, pixels, or similar technologies to build advertising profiles, to retarget you with advertising on other websites or platforms, or to engage in cross-context behavioral advertising. We do not permit third-party advertising networks to collect information about you through our Services.

Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:

  • First-Party Cookies: You can enable, disable, or delete cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Services, and/or parts of the Services may not work properly for you. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org.

Analytics. We use Vercel Web Analytics, provided by Vercel Inc. (“Vercel”), to understand how visitors find and use our Website so that we can improve it. Vercel Web Analytics does not store analytics cookies or similar identifiers on your device and does not track you across other websites. We do not enable advertising, retargeting or audience-building features, and we do not use analytics to identify you individually or to advertise to you elsewhere. As with any request to a website, the service receives technical information including your IP address, the pages you view, your referring page, and your browser and device type; we use this information only in aggregate to measure Website traffic, and we do not use it, or combine it with other information, to identify you. For more information on Vercel’s privacy practices, please visit vercel.com/legal/privacy-notice. Because this service places nothing on your device, there is no analytics cookie for you to remove through your browser’s cookie controls; if you prefer that no analytics data is collected, you can block analytics scripts using your browser’s built-in tracking protection or a content-blocking extension. If we change analytics providers, we will update this Notice and will continue to apply the limits described in this paragraph.

Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.

6. Minors

Solay Health treats patients under the age of 18. Where the patient is a minor, the account must be created and controlled by the patient’s parent or legal guardian, who enters into our Terms of Service on the minor’s behalf, provides consent to treatment, and is responsible for the account and its credentials. Minors may not create an account, accept our Terms of Service, or transact on the Website on their own behalf.

Because a minor patient’s account is held by a parent or legal guardian, the personal information and health information we collect about a minor patient is provided to us by, and accessible to, that parent or legal guardian. Sana Skin does not knowingly collect information directly from a minor without the authorization of their parent or legal guardian.

Please contact us if you believe we have collected user information about a child without consent from their parent or guardian so we can take corrective action. Requests should include a description of the specific posted information (including information that will allow us to confirm it was created and posted by you) and should be sent to shawn.thomas@solayhealth.com.

7. Security of Information

Sana Skin understands the importance of securing your information. We are continuously implementing and updating our administrative, technical, and physical security measures to protect your information.

Please be aware that using the Internet comes with inherent risks. No method of data transmission or method of physical or electronic storage can be guaranteed to be perfectly secure. There is some risk that an unauthorized third party may find a way to circumvent our security or that a transmission of your information over the Internet will be intercepted. Sana Skin takes the measures stated above to provide a level of security appropriate to the risks of processing your information. You acknowledge and accept that we cannot guarantee the security of your information.

Aside from our efforts in securing your information, it is your responsibility to protect the security of your account credentials and keep your password confidential. If you notice suspicious activity or believe that your account may have been compromised in some way, please contact us immediately at shawn.thomas@solayhealth.com.

8. Retention of Information

We may retain your information as required or permitted by applicable laws and regulations. For example, if you are a resident of certain jurisdictions you may be able to request to have your personal information deleted. If your request is granted, we may still be required by medical laws to retain your health information for a period of time. Your medical records will be retained by Company for a period of at least five (5) years, unless a longer period is required by state or federal law, after which they may be destroyed. If you are younger than twenty-three (23) years of age on the date the records may potentially be destroyed, your records will be kept at least until you reach the age of 23 or as required by state or federal law.

9. Your Choices

In order to provide our Services to you, we may send you communications related to your transactions, security, or the administration of this website. Transactional emails are emails we send you relating to your account or in connection with providing you the Services such as emails changing your account credentials, emails in response to your support request, and emails from your medical provider.

From time to time, Sana Skin may also send you marketing emails to provide you with free newsletters, surveys, offers, and other promotional materials. If you wish to stop receiving marketing emails from us, you can opt out by clicking the unsubscribe link at the bottom of any marketing email or contact us at shawn.thomas@solayhealth.com. Please be aware that you cannot opt out of transactional emails. You may opt in to receive text messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

Your patient account (your “User Account”) is hosted on the SimplePractice platform, a third-party practice-management service that acts as our service provider and is bound by a business associate agreement with respect to protected health information. You may access your User Account by going to solay.clientsecure.me and following the prompts to log in. You can edit your account information as necessary, such as your email address, name, phone number, and more. When you update your account information, we may keep a copy of your previous account details for our records and to prevent fraud or other activities that violate our terms, policies and agreements. However, if you do not provide us with some of your personal information, such as your name or email, we will no longer be able to provide you with access to our Services.

If you are a California resident, please see the next section regarding your rights.

10. California Privacy Rights

California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA)

If you are a California resident you have the following rights subject to certain exceptions:

  • The right to know what personal information we collected, the categories of sources, the business or commercial purpose for collecting it, the categories of third parties to whom we disclose it, and the specific pieces of personal information we hold about you. You may request this information beyond the prior 12-month period unless doing so would be impossible or involve disproportionate effort;

  • The right to request deletion of personal information;

  • The right to correct inaccurate personal information that we maintain about you;

  • The right to opt out of the sale or sharing of personal information, where a business engages in such activity;

  • The right to limit the use and disclosure of sensitive personal information to those uses necessary to perform the services reasonably expected by an average consumer; and

  • The right to non-discrimination for the exercise of privacy rights.

Sensitive Personal Information. Certain information we collect, including health information and precise identifiers, may be considered sensitive personal information under the CPRA. We use and disclose sensitive personal information only to provide the Services you request, to operate our business, and for the other purposes described in this Privacy Notice, and we do not use or disclose it for the purpose of inferring characteristics about you. We do not sell or share sensitive personal information.

You may submit a request to access or delete your personal information by emailing shawn.thomas@solayhealth.com. Before we approve your request(s), we will ask you to verify certain Personal Information that we have on file. Please note that requests pursuant to the CCPA are limited to non-medical personal information as the CCPA does not apply to health information governed by the CMIA.

We do not sell or share your personal information. We do not sell your personal information for monetary or other valuable consideration, and we do not share it for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA. We do not use advertising or targeting cookies, and we do not disclose identifiers such as your IP address or device ID to advertising networks. We do not sell or share the personal information of consumers we know to be under 16 years of age. Because we do not sell or share personal information, we do not offer a “Do Not Sell or Share My Personal Information” link; if this practice ever changes, we will update this Privacy Notice and provide the opt-out mechanisms required by law before doing so.

We will not discriminate against you for exercising your rights under the CCPA.

Please note that requests pursuant to the CCPA are limited to non-medical personal information as the CCPA does not apply to health information governed by the CMIA. Before we approve your request(s), we will ask you to verify certain Personal Information that we have on file. You may submit a request to access or delete your personal information by emailing shawn.thomas@solayhealth.com.

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent, you or your authorized agent must provide written proof to shawn.thomas@solayhealth.com that the agent has a valid power of attorney pursuant to California Probate Code sections 4000-4465.

The table below summarizes the categories of personal information categories, as identified by the CCPA that Sana Skin has collected in the last twelve months, and the third-parties with whom we may share your information for a business purpose as described in Section 4, above. The sources from which we collect personal information can be found in Section 2 above entitled “Sources of Information.” For purposes of this Section 10 only, “personal information” has the meaning given in the CCPA, but excludes information exempted from the scope of the CCPA, such as health information that is exempt from the CCPA, as noted above.

Categories of Personal Information CollectedCategories of Third Parties
A. IdentifiersAffiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics)
B. Certain Personal Information (§1798.8)Affiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics)
C. Certain Characteristics of Protected ClassificationsAffiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Website Optimization, Data Analytics)
D. Commercial InformationAffiliated Entities; Medical Providers; Service Providers (Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics)
E. Internet or Network Activity InformationService Providers (Customer Support/Feedback, Marketing Services, Operating Systems, Website Optimization, Data Analytics)
F. Certain Audio/Electronic/Visual/Similar InformationAffiliated Entities; Medical Providers; Service Providers (Operating Systems, Website Optimization, Data Analytics)
G. Professional/Employment-related InformationAffiliated Entities; Medical Providers; Service Providers (Talent Acquisition)
H. InferencesService Providers (Website Optimization, Data Analytics)

“Shine the Light” Law (California Civil Code § 1798.83)

California law permits California residents to request certain details about how their information is disclosed with third parties for third-party direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.

Privacy Rights for California Minors in the Digital World Act

If you are a California resident under the age of 16 and are a registered user of the Services, then you may request that we remove information you posted on the Services. Please be aware that applicable state or federal law may prevent Sana Skin from deleting certain categories of information such as health information. Request for removals should include a description of the specific posted information (including information that will allow us to confirm it was created and posted by you) and should be sent to shawn.thomas@solayhealth.com.

Do Not Track and Opt-Out Preference Signals

Certain web and mobile browsers allow you to send a signal to inform websites that you do not want your online activities tracked. Because we do not track you across other websites, do not use advertising or targeting cookies, and do not sell or share your personal information, there is no cross-context behavioral advertising for such a signal to opt you out of. Where we are required to treat an opt-out preference signal, such as Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of personal information, we will honor it.

11. International Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.

12. Updates

We may update this Privacy Notice from time to time and make changes to our information practices as permitted by law. You can reference the date on the bottom to determine when this Privacy Notice was last updated. Any changes will become effective when we post the revised Privacy Notice on the Services. If you are registered for the Services, you will be notified of any material changes to this notice prior to them becoming effective. Your use of the Services following this notice means that you acknowledge and accept the revised Privacy Notice.