Reframe
MED

Consumer Health Data Privacy Policy

Consumer Health Data Privacy Policy

Effective as of December 2025.

Glucobit Inc., doing business as Reframe and Reframe App ("Reframe," "we", "us" or "our") is dedicated to helping individuals build a healthier relationship with alcohol, regardless of the amount they consume.

This Consumer Health Data Privacy Policy ("Consumer Health Data Privacy Policy") applies to the extent required by applicable US state laws with respect to consumer health data ("Consumer Health Data") as such laws may define that term. This Consumer Health Data Privacy Policy supplements our general Privacy Policy. In the event of a conflict between our Privacy Policy and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy shall control to the extent consistent with applicable state law.

This Consumer Health Data Privacy Policy describes how Reframe processes Consumer Health Data that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, and other activities described in this Consumer Health Data Privacy Policy (collectively, the "Service").

CONSUMER HEALTH DATA WE COLLECT

Consumer Health Data you may provide to us through the Service or otherwise includes:

  • Contact data: your name, email address, billing and mailing addresses, and phone number.
  • Demographic data: your age, sex, and gender identity.
  • Profile data: the username and password you may set to establish an online account on the Service, biographical details, redemption codes, photographs or pictures, links to your social network profiles, interests, preferences, and any other information you add to your account profile.
  • Alcohol-related data: your alcohol consumption patterns and drinking goals.
  • Communications data: information from our exchanges with you, including when you contact us through the Service, social media, or other channels.
  • Transactional data: information relating to or needed to complete your orders through the Service (including order numbers and transaction history).
  • Assessment performance data: your usage, progress, and performance through the Service offerings.
  • Health-related data: your self-reported pregnancy status, medical history, prescription history, allergies, and other similar information.
  • Marketing data: your preferences for receiving our marketing communications and details about your engagement with them.
  • User-generated content data: photos, images, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where, and by whom content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
  • Payment data: information needed to complete transactions, including payment card information or bank account number.

CONSUMER HEALTH DATA WE COLLECT AUTOMATICALLY

When you use our services, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:

  • Device data: your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data: pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data: your interactions with our email, text, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

CONSUMER HEALTH DATA WE MAY CREATE, INFER OR GENERATE

We may create, infer, or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics.

CONSUMER HEALTH DATA WE OBTAIN FROM THIRD-PARTY SOURCES

We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:

  • Third-party partners: Third-party applications and services, including social networks you choose to connect with or interact with through our Service.
  • Co-branding/marketing partners: Partners with which we offer co-branded services or engage in joint marketing activities.
  • Service providers: Third parties that collect or provide Consumer Health Data in connection with work they do on our behalf.
  • Publicly available sources: Public sources of Consumer Health Data such as open government databases.

HOW WE USE YOUR CONSUMER HEALTH DATA

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

SERVICE DELIVERY AND OPERATIONS
Purpose: providing the Service, enabling security features of the Service, establishing and maintaining your user profile on the Service, communicating with you about the Service, providing support for the Service and responding to your requests/questions/feedback.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

SERVICE PERSONALIZATION
Purpose: understanding your needs and interests, personalizing your experience with the Service and our Service-related communications, remembering your selections and preferences as you navigate webpages.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

SERVICE IMPROVEMENT AND ANALYTICS
Purpose: analyzing your usage of the Service, improving the Service, improving the rest of our business, helping us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and developing new products and services.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

DIRECT MARKETING
Purpose: communicating with you about new services, upcoming events, and other information.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

INTEREST-BASED ADVERTISING
Purpose: collecting information about your interaction with the Service, our communications and other online services over time, and using that information to serve online ads that they think will interest you.
Categories of Consumer Health Data: Device data, online activity data, communications interaction data, derived data.

COMPLIANCE AND PROTECTION
Purpose: complying with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protecting our, your or others' rights, privacy, safety or property; auditing our internal processes for compliance with legal and contractual requirements or our internal policies; enforcing the terms and conditions that govern the Service; preventing, identifying, investigating and deterring fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

AGGREGATED, DE-IDENTIFIED AND/OR ANONYMIZED DATA
Purpose: We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Categories of Consumer Health Data: Contact data, demographic data, profile data, alcohol-related data, assessment performance data, communications data, marketing data, user-generated content data, payment data, transactional data, device data, online activity data, communications interaction data

HOW WE SHARE YOUR CONSUMER HEALTH DATA

We may "share" (as applicable law may define that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide the Service to you, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data with:

  • Advertising partners: Third-party advertising companies for the interest-based advertising purposes described above only to the extent such consumer health data is collected prior to your access to any authenticated pages of our websites. We do not share self-reported alcohol consumption data with advertising partners.
  • Legal and law enforcement: We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others.

YOUR CONSUMER HEALTH DATA CHOICES

You may have certain rights to your Consumer Health Data under applicable law. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge).

If you wish to exercise these rights, please email us at privacy@reframeapp.com.

  • Withdraw consent: To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.
  • Access and confirm: You have the right to ask us to confirm whether we have collected, shared or sold your Consumer Health Data. Further, you have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared or sold. You also have a right to access a list of all "third parties" (as applicable law may define that term) and affiliates with whom we have shared or sold your Consumer Health Data and receive certain corresponding information.
  • Correction: You have the right to ask us to correct inaccuracies in your Consumer Health Data.
  • Deletion: You have the right to ask us to delete your Consumer Health Data.
  • Appeal: You have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.

To exercise your rights above and make a Consumer Health Data rights request, please email us at privacy@reframeapp.com. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.

DECLINING TO PROVIDE INFORMATION

We need to collect Consumer Health Data to provide certain services. If you do not provide the information we identify as required or mandatory or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services.

CHANGES TO THIS CONSUMER HEALTH DATA PRIVACY POLICY

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Service or through other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Consumer Health Data Privacy Policy indicates your acknowledgment that the modified Consumer Health Data Privacy Policy applies to your interactions with the Service and our business.

HOW TO CONTACT US

Email: privacy@reframeapp.com

Glucobit Inc.
Atlanta, Georgia

Reframe
MED
Reframe Med+ helps you change your drinking with science based care, not shame.
Reframe helps people build a healthier relationship with alcohol using a neuroscience-based, harm-reduction approach. Our members often report meaningful benefits, including drinking less, better sleep, more energy, improved mood, money saved, and a stronger sense of wellbeing. Internal Reframe data show that a large majority of engaged members drink significantly less within the first few months of using the app. Reframe Med+ adds access to prescription medication that contains the active ingredient naltrexone, along with a personalized care plan, to create even more complete support.*
Reframe Med+ provides access to a prescription medication that includes naltrexone and is available only if prescribed by a licensed clinician through our telehealth program. When appropriate, prescriptions are filled and shipped by licensed partner pharmacies in the United States. In some cases, your prescription may be dispensed as a compounded medication tailored to your needs. Compounded drugs themselves are not reviewed by the FDA for safety, effectiveness, or quality before they are marketed.
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Reframe and Reframe Med+ are designed to support mindful drinking, moderation, or quitting. They are not emergency services and are not intended to replace inpatient detox, residential treatment, or intensive addiction care. For information about alcohol use disorder (AUD) and how to get help, please visit the NIH or SAMHSA websites. If you are in crisis, experiencing severe withdrawal, or thinking about self-harm, call your local emergency number or a crisis line right away.
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Naltrexone is the active ingredient in the medication that may be prescribed through Reframe Med+. It is an opioid receptor antagonist that has been studied as part of treatment programs for alcohol use disorder and opioid use disorder. By blocking certain opioid receptors, naltrexone can reduce the rewarding effects of alcohol and may help lower cravings when used together with counseling and behavior-change support.¹ You should not take naltrexone if you use opioids, including prescription medications or street drugs, because it can cause sudden opioid withdrawal.
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Common side effects of naltrexone may include nausea, sleepiness, headache, dizziness, vomiting, decreased appetite, muscle or joint pain, stomach discomfort, and trouble sleeping. Some people may also notice feeling more tired than usual or mild mood changes.
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More serious risks can include liver injury or allergic reactions. Stop taking your medication and contact a clinician or seek medical care right away if you experience symptoms such as severe abdominal pain, long-lasting loss of appetite, dark urine, pale stools, yellowing of the skin or eyes, chest pain, shortness of breath, swelling of the face, lips, or tongue, a rash with fever, or other signs that worry you.
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These are not all of the possible side effects or risks. Tell your clinician and pharmacist about all side effects you notice, especially those that do not go away or get worse. Only take this medication exactly as prescribed for you, and never share it with anyone else.
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* Reframe outcomes are based on internal app data and self-reported surveys from members who have engaged with the behavior-change program. These results describe the Reframe app as a whole and are not specific to Reframe Med+ or to the use of medication.
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¹ Research shows that alcohol activates the brain’s opioid system and increases dopamine release in reward pathways. Naltrexone blocks certain opioid receptors, which can reduce the rewarding effects of alcohol and help decrease cravings when it is used as part of a comprehensive treatment plan.
Reframe Partner pharmacies
Foothills Professional Pharmacy

https://www.foothillspharmacy.com/

2727 W Baseline Rd #1, Tempe, AZ 85283

480-496-4444

Additional partner pharmacies may be used depending on your state and prescription needs.
State coverage
Reframe Med+ is currently available to eligible adults in 50 states and Washington, D.C. Some services, medications, or features may not be available in every state and are subject to change based on clinical and regulatory requirements.
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