Privacy Policy

Last updated: September 16, 2026

I. Policy Purpose and To Whom It Applies

Eccentric, LLC ("Eccentric," "we," "us," or "our") is a management services organization that owns and operates https://eccentric.group (the "Site"), https://app.eccentric.group (the "Portal"), any mobile application we make available (the "App"), and related administrative services (collectively, the "Service"). This Privacy Policy describes how we collect, use, and disclose personal information when you visit or use the Service.

Eccentric provides administrative, non-clinical support to an independent, affiliated professional entity, Lance Pickard, MD and Associates, PLLC, and to any additional affiliated professional entities that may be formed in other states (collectively, the "Affiliated Practices"). The Affiliated Practices employ or contract all clinicians and are solely responsible for all clinical care, including reviewing your medical intake, ordering and interpreting laboratory results, and issuing prescriptions. The Affiliated Practices, not Eccentric, own and control your medical records.

This Privacy Policy does not apply to protected health information ("PHI") that you provide to, or that is created or maintained by, the Affiliated Practices in connection with your treatment. That information is governed by the Affiliated Practices' Notice of Privacy Practices, which is provided to you when you become a patient and is available on request through support@eccentric.group.

To the extent the Affiliated Practices are "covered entities" under the Health Insurance Portability and Accountability Act ("HIPAA"), Eccentric performs certain administrative functions on their behalf as a "business associate" pursuant to a written agreement, and PHI we handle in that capacity is used and disclosed only as permitted by HIPAA and that agreement. Regardless of HIPAA status, health-related information you provide through the Service may be protected under applicable state consumer health data and privacy laws, and we treat it as sensitive information as described in this Policy.

A. International Users; Use Outside the U.S.

The Service is intended exclusively for individuals located in the United States. If you reside outside the United States, you should not use the Service. Any information you provide may be transferred to, stored, and processed in the United States, where privacy protections may differ from those in your jurisdiction.

B. Children's Privacy

The Service is available only to individuals eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a minor, we will delete it promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@eccentric.group.

II. Personal Information We Collect & How We Collect It

"Personal Information" means any information that identifies you or that could reasonably be used, alone or in combination with other information, to identify you. Personal Information does not include information that has been de-identified, pseudonymized, anonymized, or aggregated such that it can no longer reasonably be linked to you.

A. Information You Provide to Us

Depending on how you use the Service, you may provide the following categories of Personal Information:

• Contact data: name, email address, billing and shipping addresses, and telephone numbers.
• Identity verification data: date of birth, a photograph of a government-issued ID, a selfie or other image used to match your ID, and the results of third-party identity verification, collected to confirm your identity before Services are rendered.
• Demographic information: city, state, zip code, biological sex, and age.
• Profile data: username, password, account preferences, and survey or questionnaire responses.
• Health-related information: information you enter into intake and eligibility questionnaires, including medical history, current medications, symptoms, and treatment goals; laboratory scheduling and status information; and prescription and refill status information. Health-related information is used to deliver the Service and to route your intake to the Affiliated Practices, and is not shared with third-party advertising platforms.
• Communications: the contents of emails, calls, text messages, chats, and other communications you exchange with us or with our customer-support team.
• Transactional data: order numbers, program enrollment, refill confirmations, and transaction history. Payment card numbers and related financial data are collected and processed directly by our third-party payment processor, Stripe, LLC; we receive only limited information such as the last four digits of your card, card type, and transaction status.
• Marketing data: your preferences for receiving marketing communications and details about your engagement with them.

B. Information Collected Automatically; Cookies and Trackers

When you interact with the Service, we and our service providers automatically collect certain information using cookies, pixels, web beacons, software development kits, device identifiers, and similar technologies. Providers of these technologies may include Meta, Google Analytics, Google Ads, Microsoft Advertising (Bing Ads), Hotjar, Impact, AddShoppers, X (formerly Twitter), Stripe, and similar tools.

• Performance and analytics: device type, operating system, browser type and version, IP address, general geolocation derived from IP address, pages viewed, referring URLs, time spent on pages, and interactions with features, used to measure and improve the performance of the Service.
• Advertising and marketing: advertising networks use cookies, web beacons, device identifiers, and similar technologies to collect IP addresses, browser and mobile network information, pages viewed, actions taken, time spent, links clicked, and conversion information, in order to deliver advertisements and measure their effectiveness. Health-related information and the contents of your intake questionnaires are not transmitted to advertising platforms.
• Session replay technologies: software that records clicks, touches, mouse movements, and scrolling on the Site in order to identify usability problems and optimize the Service.

III. How We Use Your Information

A. Service Delivery

We use Personal Information to:

• Provide, operate, secure, maintain, update, analyze, and improve the Service;
• Create and manage your account and verify your identity;
• Route your intake questionnaire and related information to the Affiliated Practices for clinical review;
• Coordinate laboratory scheduling, prescription fulfillment, and shipping with our laboratory and pharmacy partners on behalf of the Affiliated Practices;
• Process purchases, refill confirmations, and payments through our payment processor;
• Send administrative messages, including account notifications, refill reminders, shipping updates, security alerts, and changes to our terms and policies;
• Understand your needs and personalize your experience;
• Provide customer support and respond to your requests; and
• Send text messages as described in Section VII.

B. Marketing, Advertising, and Analytics

We may use Personal Information to send you marketing communications (subject to your consent where required), to measure the effectiveness of our marketing, and to understand how visitors use the Site.

Interest-based advertising. We work with advertising providers that use cookies and similar technologies to collect information about your interactions with the Site and other websites over time, in order to serve advertisements that may be of interest to you. Health-related information is never used for this purpose. The providers we may work with include:

• Meta Platforms: Meta uses information collected through its pixel on Facebook and Instagram in accordance with its Data Policy at facebook.com/about/privacy. You can control your ad settings at facebook.com/about/ads.
• Google Analytics and Google Ads: Google collects usage information as described at google.com/policies/privacy/partners and google.com/analytics/learn/privacy.html. You can opt out at google.com/settings/ads and by installing the Google Ads Opt-out Browser Add-on.
• Microsoft Advertising (Bing Ads): See privacy.microsoft.com/en-us/privacystatement. You can opt out at account.microsoft.com/privacy/ad-settings and account.microsoft.com/privacy/third-party-ads.
• Impact: A web analytics and affiliate-tracking service. See impact.com/privacy-policy/.
• AddShoppers: A social commerce and retargeting platform. See addshoppers.com/privacy.
• X (formerly Twitter): Advertising and analytics services. See x.com/en/privacy.

Mobile phone numbers and SMS consent data are never used for interest-based advertising and are never shared with third parties for marketing purposes.

C. Compliance and Protection

We use Personal Information to:

• Comply with applicable laws, lawful requests, and legal process;
• Enforce our Terms of Use and other agreements;
• Respond to emergencies where we believe someone's health or safety is at risk;
• Protect the rights, property, safety, and security of Eccentric, the Affiliated Practices, our users, and others;
• Audit our internal compliance processes; and
• Detect, investigate, and prevent fraud, prescription diversion, unauthorized activity, and cyberattacks.

D. Creating Anonymized, Pseudonymized, Aggregated, or De-Identified Information

We may process Personal Information to create anonymized, pseudonymized, aggregated, or de-identified data that no longer reasonably identifies you. We may use and disclose this data for our lawful business purposes, including to operate and improve the Service, for analytics, and for research and development. We commit to maintaining such data in de-identified form and not attempting to re-identify it, except as permitted by law to test the effectiveness of de-identification.

IV. To Whom We Disclose Your Information

We may disclose Personal Information to the following categories of recipients:

Affiliated Practices and healthcare parties. The Affiliated Practices and their clinicians, and the independent laboratories and pharmacies that assist with your care, to the extent necessary for treatment, payment, and healthcare operations.

Service providers. Companies that provide services on our behalf, including cloud hosting, platform maintenance, identity verification, customer support, order fulfillment and shipping, payment processing, email and SMS delivery, and analytics. Service providers are contractually restricted from using Personal Information for any purpose other than providing services to us.

Advertising and marketing providers. Companies that help us deliver and measure advertising, for the purposes described in Section III.B. We do not disclose health-related information, mobile phone numbers, or SMS consent data to these providers.

Business partners. Third parties with whom we jointly offer products, run co-marketing campaigns, or maintain affiliate or referral relationships, with your consent where required.

Professional advisors. Lawyers, accountants, auditors, bankers, and insurers in connection with the professional services they provide to us.

Authorities and others. Law enforcement, government authorities, courts, and other parties as required by law, subpoena, or legal process, or where we believe disclosure is necessary to protect rights, property, or safety.

Business transferees. Acquirers and their advisors in connection with any actual or proposed merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our business or assets. SMS consent data and text-message opt-in records will not be sold or transferred for marketing purposes; if mobile phone numbers are transferred in a business transaction, the acquirer must obtain its own consent before sending marketing messages.

Parties you authorize. Any other party to whom you direct or authorize us to disclose your information.

Selling and sharing Personal Information. We do not exchange Personal Information for money. However, our use of third-party advertising cookies and pixels may constitute a "sale" or "sharing" of Personal Information (or "targeted advertising") under certain state privacy laws. You can opt out as described in Sections VI and VIII. We do not sell or share health-related information, identity verification data, mobile phone numbers, or SMS consent data.

V. Summary Chart — How We Use and Share Your Personal Information

VI. Your Choices

Access, Update, or Delete Your Information

If you have an account, you may review and update certain information through your account settings, or contact us using the information in Section XIV. Requests relating to your medical records should be directed to the Affiliated Practices as described in Section XIV.

Opt Out of Marketing Emails

You may unsubscribe from marketing emails by clicking the unsubscribe link in any marketing email or by contacting support@eccentric.group. You will continue to receive service-related, non-marketing emails.

Mobile Location Data

If you use the App, you can disable precise geolocation access through your mobile device settings.

Advertising Choices

You may limit interest-based advertising by:

• Using the "Your Privacy Choices" link on the Site;
• Blocking third-party cookies in your browser settings;
• Using a privacy-focused browser or ad-blocking extension;
• Adjusting your mobile device settings to limit use of the advertising identifier; and
• Using the opt-out tools offered by the advertising providers listed in Section III.B.

Opt-out settings are device- and browser-specific and must be set separately on each device you use.

Do Not Track and Opt-Out Preference Signals

We do not currently respond to browser "Do Not Track" signals. We do recognize opt-out preference signals, such as Global Privacy Control, that are transmitted by your browser or extension, and treat them as a request to opt out of the sale or sharing of Personal Information and targeted advertising for that browser.

Logins via Third-Party Platforms

If you sign in using a third-party account (for example, Google or Apple), you can limit the information we receive by adjusting your settings on that platform. Revoking access does not affect information we have already received.

VII. SMS and Text Message Communications

A. Why We Collect Your Number and How We Obtain Consent

We collect your mobile phone number to verify your identity when you sign in and to communicate with you about your account and Services. We obtain your consent to text messaging through a checkbox at sign-up. Consent to receive text messages is not a condition of purchasing any Service.

B. Types of Messages

1. Authentication messages: one-time codes that you request in order to sign in or confirm sensitive actions.
2. Service messages: notifications related to your account and Services, including intake reminders, lab appointment details, refill confirmations, shipping updates, payment confirmations, and security alerts, sent based on the consent you provide at sign-up.
3. Marketing messages: promotional messages, sent only with your separate, express consent.

C. Message Frequency and Rates

Message frequency varies based on your account activity. Message and data rates may apply. Wireless carriers are not liable for delayed or undelivered messages.

D. How to Get Help

Reply HELP to any message or contact support@eccentric.group.

E. How to Stop Text Messages

You may withdraw consent at any time by replying STOP to any message or by contacting support@eccentric.group.

• Replying STOP stops messages from the number you replied to. If you receive messages from more than one number, reply STOP to each, or contact support to stop all messages.
• Opting out of marketing messages does not stop service or authentication messages.
• Opting out of all messages will prevent you from signing in by text-message code; you may need to use an alternative sign-in method.
• If your request is unclear, we may send one message asking you to clarify. If you do not respond, we will treat your request as applying to all messages that require your consent.

STOP replies are processed immediately. Requests made through other methods are honored within ten (10) business days. If you opt out and later wish to rejoin, you may re-enroll through the Platform.

F. No Sharing of Mobile Information

Your mobile phone number and SMS consent data will not be shared with third parties or affiliates for marketing or promotional purposes, and will never be sold. If mobile numbers are transferred in a business transaction, the acquirer must obtain its own consent before sending marketing messages. We may share mobile information with subcontractors that deliver SMS messages or provide customer support on our behalf, solely for that purpose.

VIII. Your Privacy Rights

If you reside in a state with a comprehensive consumer privacy law (including, for example, California, Colorado, Connecticut, Texas, Virginia, and others), you may have some or all of the following rights ("Data Subject Rights"), subject to applicable exceptions:

• Right to confirm, access, and obtain a copy: to confirm whether we process your Personal Information and to receive a copy of it.
• Right to correct: to request correction of inaccurate or incomplete Personal Information.
• Right to delete: to request deletion of your Personal Information.
• Right to portability: to receive your Personal Information in a portable, readily usable electronic format.
• Right to withdraw consent or opt out: to withdraw consent or restrict processing, including processing of sensitive Personal Information.
• Right to limit use of sensitive Personal Information: to direct us to limit use of sensitive information to purposes permitted by law, via "Your Privacy Choices" on the Site.
• Right to opt out of targeted advertising: to opt out of interest-based or cross-context behavioral advertising, via "Your Privacy Choices" or the provider-specific tools in Section III.B.
• Right to opt out of sales or sharing: to direct us not to sell or share your Personal Information, via "Your Privacy Choices."
• Right to non-discrimination: we will not discriminate against you for exercising your rights, although we may charge a reasonable fee for excessive or repetitive requests where permitted by law.
• Right to appeal: if we deny your request, you may appeal within forty-five (45) days by emailing privacy@eccentric.group with the subject line "Privacy Appeal" and a description of your original request. We will respond within forty-five (45) days.
• Right to complain to a regulator: you may submit a complaint to your state attorney general or other applicable regulator.

To exercise these rights, contact us as described in Section XIV. We will respond within forty-five (45) days, which we may extend once by an additional forty-five (45) days where reasonably necessary. We may need to verify your identity before fulfilling a request. An authorized agent may submit a request on your behalf with written proof of authorization; we may also require you to verify your identity directly.

Requests relating to PHI held by the Affiliated Practices, including requests to access, amend, or obtain a copy of your medical records, are governed by the Affiliated Practices' Notice of Privacy Practices and should be directed as described in Section XIV.

IX. Artificial Intelligence-Enabled Tools

The Service may include tools that use artificial intelligence ("AI Tools") to enhance your experience and support customer service and administrative functions. AI Tools do not provide medical advice and do not make clinical decisions; all clinical determinations are made by the clinicians of the Affiliated Practices. Your use of AI Tools is governed by our Terms of Use.

AI Tools we may use:

• Intercom Fin AI-powered chatbot: a natural-language chat assistant that answers account, logistics, and general support questions.
• Zoom: video visit hosting, with transcription, recording, and analytics features.
• Fireflies.ai: transcription of video meetings for note-taking and quality assurance.
• OpenAI: transcription, summarization, and analytics services that power certain features above.

Data sharing and protection. Information you provide while interacting with an AI Tool may be retained by us to analyze, improve, and fine-tune the Service, and may be transmitted to the AI Tool vendor's systems to generate responses. Each vendor is bound by a data processing agreement (for example, Intercom's Data Processing Addendum, OpenAI's Data Processing Addendum and enterprise privacy commitments, Zoom's Data Processing Addendum, and Fireflies.ai's Data Processing Agreement) that restricts use of your information to providing the service to us.

Consent and alternatives. By interacting with an AI Tool, you consent to the processing described above. If you prefer not to share information with an AI Tool, you may contact our support team directly at support@eccentric.group or by phone at (713) 396-2030.

Updates. We may modify our use of AI Tools and will update this Policy accordingly.

X. Other Sites and Services

The Service may contain links to third-party websites, applications, and services, including those operated by laboratories, pharmacies, payment processors, and identity verification providers. We do not control these third parties and are not responsible for their privacy practices. Information you provide directly to a third party is governed by that party's privacy policy, which we encourage you to review.

XI. State-Specific Notices

A. Notice to Washington and Nevada Residents

If you are a resident of Washington or Nevada, please refer to our Consumer Health Data Privacy Policy, available on the Site, for additional information about how we collect, use, and disclose "consumer health data" under the Washington My Health My Data Act and Nevada's consumer health data law.

B. Notice to Texas Residents

If you are a Texas resident, you have the rights described in Section VIII under the Texas Data Privacy and Security Act. In addition, health-related information you provide through the Service may be protected under Texas law, including the Texas Medical Records Privacy Act, and is not sold or used for marketing without your consent.

C. Notice to California Residents

This section provides additional disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

Categories of Personal Information collected. In the preceding twelve (12) months, we may have collected the following categories of Personal Information, as described in Section II: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); protected classification characteristics; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or similar information; and inferences drawn from the foregoing. We may also have collected the following categories of sensitive Personal Information: health information; government-issued identification numbers and images (for identity verification); account log-in credentials; precise geolocation (if enabled in the App); and the contents of customer-service communications.

Use of sensitive Personal Information. We use sensitive Personal Information only for purposes permitted by the CCPA, including to provide the Service you request, to verify your identity, to prevent fraud, and to ensure security. You may direct us to limit use of sensitive Personal Information via "Your Privacy Choices" on the Site.

Business or commercial purposes. We collect Personal Information for the purposes described in Section III and the Summary Chart in Section V.

Categories of sources. We collect Personal Information from the sources described in Section II.

Categories of third parties. We disclose Personal Information to the categories of third parties described in Section IV and the Summary Chart in Section V.

Sale or sharing of Personal Information. We engage in cross-context behavioral advertising, which may constitute "selling" or "sharing" Personal Information under the CCPA. In the preceding twelve (12) months, we may have sold or shared identifiers (excluding mobile phone numbers), commercial information (conversion data only), and internet or other electronic network activity information with data analytics providers, advertising networks, and social media networks. We do not sell or share health information, identity verification data, mobile phone numbers, or SMS consent data, and we do not knowingly sell or share the Personal Information of anyone under 16. You may opt out via "Your Privacy Choices" on the Site.

Retention. We retain each category of Personal Information for as long as reasonably necessary to fulfill the purposes described in this Policy, to comply with legal, tax, and regulatory obligations, to resolve disputes, and to enforce our agreements, after which it is deleted or de-identified.

Shine the Light. Under California Civil Code § 1798.83, California residents may request, once per year, information about our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, contact us as described in Section XIV.

XII. Security

We maintain technical, organizational, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and disclosure. These include encryption of data in transit and at rest, access controls, and periodic security reviews. However, no method of transmission or storage is completely secure, and we cannot guarantee that unauthorized access, theft, or modification will never occur. You are responsible for keeping your log-in credentials confidential. If we learn of a security incident affecting your Personal Information, we will notify you and any applicable regulators as required by law.

XIII. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. If we make material changes, we will notify you through the Service, by email, or as otherwise required by law, and we will update the "Last updated" date above. Changes take effect on the date stated. Your continued use of the Service after the effective date constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

XIV. Contact Us

For questions about this Privacy Policy or to exercise your privacy rights:

By email: privacy@eccentric.group

By phone: (713) 396-2030

By mail:
Eccentric, LLC
Attn: Privacy
275 Pine Hollow Ln
Houston, TX 77027

Data Subject Rights requests. You may exercise your rights through the following links on the Site, or by emailing privacy@eccentric.group with the subject line "Privacy Request":

• Delete your information
• Know what information we have collected
• Correct your information
• Opt out of cookies and trackers ("Your Privacy Choices")

These rights apply to Personal Information collected by Eccentric, LLC. Requests relating to your medical records, or to PHI held by Lance Pickard, MD and Associates, PLLC or another Affiliated Practice, should be sent to support@eccentric.group, and we will route them to the Affiliated Practice for response.

Additional Information for Job Applicants

This section supplements the Policy for individuals who apply for employment with Eccentric. We may collect Personal Information from you directly, from publicly available sources, from background-check and data analytics providers, and from sources you authorize, such as former employers and references.

Categories collected may include the following (items marked with an asterisk (*) are "sensitive" under the CCPA):

• Identifiers*: name, contact details, and government-issued identification numbers (such as Social Security, driver's license, passport, or state ID numbers).
• Demographics and protected classifications*: citizenship or work authorization status, gender, date of birth, age, race, ethnicity, marital status, veteran or military status, and disability or medical status (collected only where permitted by law and for accommodation or equal-opportunity reporting purposes).
• Professional and employment information: employment history, employer names, positions held, professional licenses and associations, references, and compensation history where permitted by law.
• Educational information: institutions attended, degrees, certifications, and related records.

We use this information to evaluate your application, verify your qualifications, conduct background checks where permitted, comply with legal obligations, and communicate with you. Further details on use and disclosure appear in Sections III and IV.