Privacy Policy
Read the Privacy Policy for Keen, operated by Keen Meds Inc. Learn how we collect, use, and protect your personal and health information at livekeen.co.
Overview
PLEASE READ THIS PRIVACY POLICY ("POLICY") CAREFULLY. IT DESCRIBES HOW KEEN MEDS INC. ("KEEN MEDS," "WE," "US," OR "OUR") COLLECTS, USES, DISCLOSES, AND SAFEGUARDS YOUR INFORMATION WHEN YOU ACCESS OR USE OUR WEBSITE (LIVEKEEN.CO), MOBILE APPLICATION, OR ANY RELATED SERVICES (COLLECTIVELY, THE "PLATFORM"). BY ACCESSING OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.
IMPORTANT: THIS POLICY DOES NOT REPLACE THE NOTICE OF PRIVACY PRACTICES ISSUED BY OUR AFFILIATED MEDICAL PRACTICE, THE HIPAA-COVERED ENTITY RESPONSIBLE FOR YOUR PROTECTED HEALTH INFORMATION (PHI). FOR INFORMATION ABOUT HOW YOUR PHI IS USED AND DISCLOSED UNDER HIPAA, PLEASE REVIEW OUR HIPAA NOTICE.
1. Introduction
1.1 About Keen. Keen (operated by Keen Meds Inc., "Keen Meds," "we," "us," "our") is a Delaware corporation with its principal office at 1550 Wewatta Street, Suite 200, Denver, CO 80202. Keen operates a technology platform that facilitates access to telehealth services, prescription fulfillment, and related offerings through the website located at livekeen.co (the "Platform").
1.2 Three-Party Service Model. The Platform involves three independent entities:
- Keen Meds Inc. provides the technology platform, membership management, billing, customer support, intake coordination, and product fulfillment logistics.
- Our affiliated medical practice is an independent medical practice that employs or contracts with licensed clinicians who conduct telehealth consultations, make medical assessments, and issue prescriptions when clinically appropriate. Our affiliated medical practice is a HIPAA-covered entity responsible for the privacy and security of Protected Health Information (PHI).
- Our partner pharmacy is an independent, licensed 503A compounding pharmacy that compounds, verifies, dispenses, and ships prescription medications pursuant to valid, patient-specific prescriptions.
The specific entities providing medical and pharmacy services are identified in Section 16 (Service Partners and Payment Processor) of this Policy.
1.3 Scope. This Privacy Policy applies to all personal information collected through the Platform, including information you provide directly, information collected automatically, and information received from third parties. This Policy does not apply to information collected by our affiliated medical practice or our partner pharmacy under their own privacy policies, except to the extent that such information is shared with Keen Meds.
1.4 HIPAA Business Associate Status. Keen Meds acts as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") with respect to PHI processed on behalf of our affiliated medical practice. Keen Meds maintains a Business Associate Agreement (BAA) with our affiliated medical practice governing the handling, security, and permitted uses of PHI. For complete information about your HIPAA rights and how your health information is used and disclosed, please refer to our HIPAA Notice.
2. Information We Collect
2.1 Information You Provide Directly
We collect information you voluntarily provide to us, including:
- Contact Information: Name, email address, phone number, mailing address. For details on how we collect and use your phone number for SMS communications, please see our SMS Consent Policy.
- Account Information: Username, password, account preferences.
- Health Information: Health history, current medications, medical conditions, symptoms, and other information submitted through the health intake process. This information is collected to facilitate clinical consultations with our affiliated medical practice's providers.
- Prescription Information: Prescriptions filled through our partner pharmacy, dosage information, medication allergies, and delivery preferences.
- Payment Information: Billing address, payment method details. Payment information is processed securely through Stripe, our payment processor; Keen Meds does not store your full credit card number on its servers.
- Communications: Messages, requests, feedback, testimonials, and customer support inquiries you submit to us.
- Identity Verification: Government-issued identification, date of birth, and other identity-verifying information required for controlled substance prescriptions and regulatory compliance.
- 2.2 Information Collected Automatically
When you access our Platform, we automatically collect:
- Device Information: IP address, device type, operating system, browser type, device identifiers, and screen resolution.
- Usage Data: Pages visited, time spent on pages, click patterns, referring URLs, search queries, and navigation paths.
- Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to recognize your device, maintain your session, and improve your experience. See Section 6 for more detail.
- Location Data: Approximate geographic location based on your IP address. We do not collect precise geolocation unless you provide explicit permission.
- 2.3 Information from Third Parties
We may receive information about you from:
- Our Affiliated Medical Practice: Healthcare providers affiliated with our medical practice partner share medical information, consultation notes, treatment plans, and health assessments as necessary to facilitate your care through the Platform.
- Our Partner Pharmacy: Prescription history, medication fulfillment status, and pharmacy records.
- Laboratory Partners: Lab test results and diagnostic reports related to your health monitoring.
- Payment Processors: Transaction confirmation, billing verification, and fraud-prevention data.
- Public Sources: Information from publicly available sources, only to the extent necessary for identity verification, fraud prevention, or legal compliance.
- 2.4 Consumer Health Data
Consumer health data includes information that can identify you and relates to your health or healthcare, including personal identifiers, medical history, medications, prescriptions, clinical notes, test results, billing information, and appointment history. This data is subject to additional protections under applicable state consumer health data privacy laws.
2.5 Sensitive Personal Information
Under applicable state privacy laws, including the CCPA/CPRA, certain categories of information we collect are classified as "sensitive personal information." These include:
- Health information — medical history, diagnoses, prescriptions, lab results, treatment plans, and clinical notes collected through the health intake and consultation process.
- Government-issued identification — driver's license or state ID numbers collected for identity verification purposes (particularly for controlled substance prescriptions).
- Account credentials — login credentials (username and password) used to access your account.
- Precise geolocation — if you grant location permissions (we do not collect precise geolocation by default).
Keen Meds uses sensitive personal information only for purposes necessary to provide the Services, including facilitating telehealth consultations, coordinating prescription fulfillment, verifying your identity, ensuring regulatory compliance, and protecting the security of the Platform. We do not use sensitive personal information for profiling or advertising purposes. Under the CCPA/CPRA, you have the right to limit our use of sensitive personal information to necessary business purposes. To exercise this right, contact us at support@livekeen.co.
3. How We Use Your Information
3.1 Providing Platform Services. We use your information to operate the Platform, facilitate telehealth consultations with our affiliated medical practice's providers, coordinate prescription fulfillment through our partner pharmacy, manage your account, process transactions, and deliver our services.
3.2 Patient Care Coordination. Your medical information is shared with our affiliated medical practice's healthcare providers to facilitate clinical consultations, treatment planning, health monitoring, and prescription coordination with our partner pharmacy. Keen Meds does not make medical decisions; all clinical decisions are made by our affiliated medical practice's providers.
3.3 Billing and Payment Processing. We use your payment information to process Membership charges, product purchases, and related transactions. Payment processing is handled by Stripe in compliance with Payment Card Industry Data Security Standards (PCI-DSS).
3.4 Compliance and Legal Obligations. We use your information to comply with applicable federal and state laws, including HIPAA, state privacy laws, tax obligations, controlled substance reporting requirements, fraud prevention, and responses to lawful requests from courts or law enforcement.
3.5 Platform Improvement and Analytics. We use usage data and analytics to improve the Platform, enhance user experience, troubleshoot technical issues, and develop new features. This analysis is typically conducted on de-identified or aggregated data.
3.6 Communication and Customer Support. We use your contact information to respond to inquiries, provide customer support, send appointment reminders, prescription refill notifications, shipping updates, and important Platform notices. You may opt out of non-essential communications as described in Section 8.
3.7 Marketing and Promotional Activities. With your consent, we may send newsletters, promotional offers, and educational content about our services. You may opt out of marketing communications at any time by clicking "Unsubscribe" in any promotional email, adjusting your account preferences, or contacting us at support@livekeen.co.
3.8 Safety and Security. We use your information to detect, investigate, and prevent fraud, unauthorized access, and other illegal or harmful activities, and to protect the safety and security of the Platform, our users, and our partners.
5. Protected Health Information and HIPAA
5.1 HIPAA Covered Entity and Business Associate Relationship. Our affiliated medical practice (identified in Section 16) is the HIPAA-covered entity responsible for your Protected Health Information (PHI). Keen Meds acts as a Business Associate under HIPAA and has entered into a Business Associate Agreement (BAA) with our affiliated medical practice to ensure compliance with HIPAA's Privacy Rule, Security Rule, and Breach Notification Rule.
5.2 Authorized Uses and Disclosures of PHI. Keen Meds uses and discloses your PHI only as permitted by the BAA, including: to provide, bill for, and coordinate telehealth services through our affiliated medical practice; as required by law; as directed by our affiliated medical practice to fulfill its obligations; and as authorized by a valid Business Associate Agreement.
5.3 Your HIPAA Rights. Under HIPAA, you have the right to:
- Access your Protected Health Information.
- Request amendments to your health records.
- Request an accounting of disclosures of your PHI.
- Request restrictions on certain uses and disclosures.
- Request confidential communications.
- Receive notice of privacy practices.
- File complaints regarding privacy violations with the U.S. Department of Health and Human Services, Office for Civil Rights (HHS OCR).
To exercise these rights, contact our affiliated medical practice directly or submit requests through the Platform at support@livekeen.co, and your request will be forwarded to our affiliated medical practice for processing. For complete HIPAA rights information, please review our HIPAA Notice.
5.4 Breach Notification. In the event of an unauthorized acquisition, access, use, or disclosure of your PHI that compromises its security or privacy, Keen Meds will notify you in accordance with HIPAA's Breach Notification Rule without unreasonable delay and no later than sixty (60) calendar days after discovery of the breach. Notification will be sent to the contact information on file.
7. Your Rights and Choices
7.1 Access and Portability. You have the right to access your personal information and request a copy in a portable, machine-readable format. To submit an access request, contact us at support@livekeen.co.
7.2 Correction and Updates. You may correct, update, or amend your personal information by logging into your account or contacting us at support@livekeen.co. If you believe we maintain inaccurate health information, you may request correction through your healthcare provider or through us.
7.3 Deletion. Subject to legal and regulatory requirements, you may request deletion of your personal information. Please note that we must retain certain information for compliance with HIPAA, controlled substance record-keeping requirements, tax obligations, and other legal obligations. To request deletion, contact us at support@livekeen.co.
7.4 Marketing Communications. You may opt out of marketing emails by clicking "Unsubscribe" in any promotional email, adjusting your account preferences, or contacting us at support@livekeen.co. Opting out of marketing communications does not affect transactional or service-related communications (e.g., appointment reminders, prescription notifications, billing notices).
7.5 Cookie and Tracking Choices. You can control cookies through your browser settings, disable tracking pixels, and opt out of third-party advertising through industry tools such as the NAI or DAA opt-out mechanisms described in Section 6.5.
7.6 Non-Discrimination. We will not discriminate against you for exercising any of your privacy rights. You will not receive different pricing, quality of service, or access to the Platform as a result of exercising your rights under this Policy or applicable law.
8. State-Specific Privacy Rights
Depending on your state of residence, you may have additional privacy rights under state law. This Section summarizes your rights under specific state privacy laws. To exercise any of these rights, contact us at support@livekeen.co or legal@livekeen.co. We will verify your identity and respond within the timeframe required by applicable law.
8.1 California (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act provide you with the following rights:
- Right to Know: You have the right to know what personal information we collect, use, share, and sell.
- Right to Access: You have the right to request a copy of the personal information we have collected about you in a portable format.
- Right to Delete: You have the right to request deletion of your personal information, subject to legal exceptions.
- Right to Correct: You have the right to request correction of inaccurate personal information.
- Right to Opt Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your personal information. Keen Meds does not sell your personal information.
- Right to Limit Sensitive Personal Information: You have the right to limit our use of sensitive personal information to necessary business purposes.
- Right to Opt Out of Automated Decision-Making: You have the right to opt out of automated decision-making, including profiling.
- Non-Discrimination: You will not be discriminated against for exercising your CCPA/CPRA rights.
To submit a request, contact us at support@livekeen.co. We will verify your identity and respond within forty-five (45) days. You may also designate an authorized agent to make a request on your behalf.
Notice to California Residents: The California Attorney General maintains information about entities subject to the California Consumer Privacy Act at oag.ca.gov. If you have an unresolved privacy complaint, you may report it to the California Attorney General.
8.2 Colorado (CPA)
If you are a Colorado resident, the Colorado Privacy Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising, profiling for decisions that produce legal or similarly significant effects, and the sale of personal data. To submit a request, contact us at support@livekeen.co.
8.3 Connecticut (CTDPA)
If you are a Connecticut resident, the Connecticut Data Privacy Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising, the sale of personal data, and profiling that produces legal or similarly significant effects. To submit a request, contact us at support@livekeen.co.
8.4 Virginia (VCDPA)
If you are a Virginia resident, the Virginia Consumer Data Protection Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising, the sale of personal data, and profiling that produces legal or similarly significant effects. To submit a request, contact us at support@livekeen.co. If we decline your request, you have the right to appeal by contacting us at legal@livekeen.co.
8.5 Nevada (NRS 603A)
If you are a Nevada resident, you have the right to opt out of the sale of your personal information. Keen Meds does not currently sell your personal information. If you wish to submit an opt-out request, contact us at support@livekeen.co with "Nevada Opt-Out" in the subject line.
8.6 Texas (TDPSA)
If you are a Texas resident, the Texas Data Privacy and Security Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising and the sale of personal data. To submit a request, contact us at support@livekeen.co.
8.7 Oregon (OCPA)
If you are an Oregon resident, the Oregon Consumer Privacy Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising and the sale of personal data. To submit a request, contact us at support@livekeen.co.
8.8 Montana (MCDPA)
If you are a Montana resident, the Montana Consumer Data Privacy Act provides you with the right to access, correct, delete, and obtain a portable copy of your personal data. You may also opt out of targeted advertising and the sale of personal data. To submit a request, contact us at support@livekeen.co.
8.9 Washington (My Health My Data Act)
If you are a Washington resident, the My Health My Data Act provides you with the following rights regarding your consumer health data:
- The right to know whether your health data is collected, used, or shared.
- The right to access your health data.
- The right to request deletion of your health data.
- The right to correct inaccurate health data.
- The right to opt out of the sale or sharing of your health data.
Keen Meds does not sell your health information without your explicit consent. To submit a request, contact us at support@livekeen.co.
9. Data Security
9.1 Security Measures. Keen Meds implements comprehensive administrative, technical, and physical safeguards to protect your personal information and Protected Health Information from unauthorized access, disclosure, alteration, and destruction. These safeguards include:
- Encryption of data in transit (TLS/SSL) and at rest (AES-256).
- Secure password policies and multi-factor authentication (MFA).
- Regular security audits, penetration testing, and vulnerability assessments.
- Role-based access controls limiting employee access to information on a need-to-know basis.
- Secure data centers with physical access controls and monitoring.
- HIPAA-compliant audit logs and activity monitoring.
- Annual employee and workforce training on privacy and security best practices.
- Incident response and breach notification procedures.
9.2 Limitations. While we implement robust security measures, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your information. You acknowledge the inherent risks of electronic communication and agree not to transmit highly sensitive information (e.g., Social Security numbers, government-issued identification numbers) through unsecured channels such as unencrypted email.
10. Data Retention
10.1 Retention Periods. Keen Meds retains your information for as long as necessary to provide Services, comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods vary based on the type of information:
- Protected Health Information: Retained for the duration of the patient-provider relationship plus a minimum of six (6) years, or longer as required by applicable state law (some states require longer retention for minors).
- Account Information: Retained for the duration of your account plus up to two (2) years after account closure.
- Billing and Payment Records: Retained for seven (7) years for tax, audit, and legal compliance.
- Usage and Analytics Data: Aggregated and de-identified data may be retained indefinitely for analytics and service improvement purposes.
- Marketing Preferences: Retained until you unsubscribe or request removal.
- Controlled Substance Records: Retained as required by DEA regulations and applicable state law.
10.2 Secure Disposal. When information is no longer needed and no longer subject to any legal retention requirement, we securely delete or de-identify it in accordance with HIPAA standards, NIST guidelines, and applicable state law.
11. Children's Privacy
11.1 The Platform is not intended for children under the age of eighteen (18). We do not knowingly collect personal information from children under eighteen without parental or legal guardian consent. The Platform is prohibited for use by individuals under the age of thirteen (13).
11.2 If you believe we have collected information from a child under eighteen without proper consent, please contact us immediately at support@livekeen.co. We will take steps to promptly delete such information.
11.3 For minors between the ages of thirteen (13) and seventeen (17) using the Platform with verifiable parental consent, parents or legal guardians may request access to, correction of, or deletion of the minor's information by contacting us at support@livekeen.co.
12. Third-Party Links
12.1 The Platform may contain links to third-party websites, applications, and services (including payment processors, laboratory services, health information resources, and social media platforms). This Privacy Policy applies only to the Keen Meds Platform and does not govern the practices of third-party websites or services.
12.2 When you access third-party services through links on the Platform, you are subject to their privacy policies and terms of service. We are not responsible for the privacy practices, content, or security of any third-party website or service.
12.3 We encourage you to review the privacy policy of any third-party service before providing your personal information.
13. International Data Transfers
13.1 Keen Meds operates primarily within the United States. Your information is stored and processed in the United States.
13.2 If you are located outside the United States, please be aware that by using the Platform, your information will be transferred to, stored in, and processed in the United States. The United States may not offer the same level of data protection as your home country.
13.3 By using the Platform, you consent to the transfer of your information to the United States and its processing under U.S. law. If you do not consent to this transfer, please do not use the Platform.
14. Changes to This Privacy Policy
14.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, and other factors.
14.2 We will notify you of material changes by:
- Posting the updated Privacy Policy on the Platform with a new "Effective Date" and "Last Updated" date.
- Sending an email notification to the email address associated with your account if the changes significantly impact your privacy rights.
- Requesting your explicit consent if the changes materially alter how we handle Protected Health Information.
14.3 Your continued use of the Platform after changes have been posted constitutes your acceptance of the updated Privacy Policy. If you do not agree to the changes, you should discontinue use of the Platform and contact us to close your account.
14.4 We encourage you to review this Policy periodically to stay informed about how we protect your information.
15. Contact US
For questions about this Privacy Policy, to exercise your privacy rights, or to report a concern about our privacy practices, please contact us:
Keen Meds Inc.
1550 Wewatta Street, Suite 200
Denver, CO 80202
Email: support@livekeen.co
Privacy Inquiries: privacy@livekeen.co
Legal Inquiries: legal@livekeen.co
General Questions: ask@livekeen.co
Website: livekeen.co
When submitting a privacy-related request, please email privacy@livekeen.co and include "Privacy Request" or the specific right you wish to exercise (e.g., "CCPA Access Request," "Deletion Request") in the subject line and provide sufficient information to verify your identity.
Notice to California Residents: If you have an unresolved privacy complaint, you may report it to the California Attorney General at oag.ca.gov.
HIPAA Complaints: For issues related to your Protected Health Information and healthcare privacy concerns, you may file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights (HHS OCR) at ocrportal.hhs.gov or by calling 1-800-HHS-TIPS (1-800-447-8477).
16. Service Partners and Payment Processor
The following independent entities provide medical, pharmacy, and payment services in connection with the Platform:
16.1 Medical Practice
Beluga Health P.A. is the independent medical practice and HIPAA-covered entity whose licensed clinicians provide telehealth consultations, make clinical assessments, and issue prescriptions. Contact: privacy@belugahealth.com.
16.2 Pharmacy
The Pharmacy Hub is the independent, licensed 503A compounding pharmacy that compounds, verifies, dispenses, and ships prescription medications.
16.3 Payment Processor
Stripe processes all payments on behalf of Keen Meds. Payment information is handled in accordance with PCI-DSS standards. Stripe's privacy policy is available at stripe.com/privacy.
17. Additional Disclosures
17.1 Governing Law. This Privacy Policy is governed by and construed in accordance with the laws of the State of Delaware, without regard to conflict-of-laws principles, except to the extent preempted by federal law (including HIPAA).
17.2 Related Policies. This Privacy Policy should be read in conjunction with our Terms and Conditions and HIPAA Notice, which are incorporated herein by reference.
17.3 Severability. If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.