Privacy Policy

Effective July 27, 2026 · Last updated October 29, 2026

CellThrive is operated by Framework Wellness LLC ("CellThrive," "we," "us," or "our"). CellThrive is an online health membership: we provide personalized educational health insights and help members arrange laboratory and genetic testing through independent partners. CellThrive does not provide medical care. We take the privacy and security of your information seriously, especially your health information. This Privacy Policy explains what we collect, how we use and share it, the choices you have, and how we protect it.

This Policy explains how we handle your information. Where the law requires your consent, we ask for it separately and in advance; using our website or accepting our Terms of Use is not consent to anything in this Policy that requires your separate consent.

1. Scope

This Policy applies to information we collect through cellthrive.health, our member portal, our assessments and forms, our communications with you, and related services (the "Services"). It does not apply to third parties we do not control, such as laboratories and other service providers, each of whom maintains its own privacy practices.

2. Information We Collect

Information you provide

  • Account & contact information — name, email, phone, mailing address, and login credentials.
  • Health assessment responses — symptoms, goals, health history, supplements, and allergies you submit.
  • Laboratory results — blood and other lab test results ordered through licensed laboratories.
  • Genetic information — data derived from a DNA sample or raw genetic file you provide or authorize us to process.
  • Wearable and device data — if you connect a device (e.g., an Oura Ring), the metrics you authorize us to receive.
  • Payment information — processed by our third-party payment processors; we do not store full card numbers.
  • Communications — messages, emails and texts exchanged with our team, and, if you speak with our team by phone or video, call recordings and notes.

Information collected automatically

  • Usage and technical data — device type, browser, IP address, pages viewed, and interactions, collected through cookies and similar technologies.

3. Consumer Health Data & Your Consent

Some information we collect — including your assessment responses, lab results, genetic data, and device metrics — is "consumer health data" under applicable state laws (such as the Washington My Health My Data Act and comparable laws in Nevada, Connecticut, and other states). Our Consumer Health Data Privacy Policy, linked at the bottom of our website pages, explains exactly what we collect, where it comes from, who receives it, and how to use your rights.

  • We collect consumer health data only with your consent or as necessary to provide the membership or services you request.
  • We share it only as described in Section 5, and where a state law requires separate consent to share, we will obtain that consent from you.
  • You may withdraw consent or request deletion of your consumer health data at any time in your account or at cellthrive.health/privacy-request (see Section 10). Withdrawing consent may limit or end our ability to provide the Services.
  • We do not sell your consumer health data, and we do not use it to target advertising to you.

4. How We Use Your Information

  • To provide the Services — build your health map and personalized educational health insights, and arrange the lab and genetic tests you order.
  • To communicate with you about your results, orders, membership, and account, and — if you have not opted out — to send you marketing emails and, only if you separately opt in, marketing text messages.
  • To process payments and manage your membership.
  • To operate, secure, maintain, and improve our Services.
  • To comply with legal obligations and enforce our terms.
  • With your separate opt-in, we may use de-identified answers, lab results and plan adherence to study which recommendations work and share de-identified findings with research partners or publications.

5. How We Share Your Information

We share your information only as necessary to deliver the Services and as described below. We do not sell your personal information or your health information.

  • CellThrive staff — the team members who support your membership, each bound by a duty of confidentiality.
  • Laboratories — licensed labs that perform your testing.
  • Service providers — vendors who process data on our behalf under contracts requiring them to protect your information and use it only for services provided to us: hosting and database, sign-in, email and text delivery, payment processing, scheduling, customer-relationship management, phone and video calls with call recording and transcription, report generation, and AI tools that help us run the service (for example, to produce your insights, summarize calls, and read lab files).
  • Testing partners — when you order a lab panel or genetic test, we send the information needed to fulfill it (such as your name, date of birth, sex, contact details, and the tests ordered) to our lab-ordering partner, the laboratory, and the genetic-test kit provider.
  • Supplement dispensary — when you choose to order supplements, we send your name, contact details, and the products you selected to our dispensary partner, which fills your order under its own privacy policy.
  • Connected devices and apps — if you choose to connect a device or app (such as an Oura Ring), we receive the data you authorize from that service.
  • Social media messages — if you message us on Facebook or Instagram, Meta processes those messages under its own policy.
  • Legal & safety — when required by law or valid legal process, or to protect rights, safety, and property. We disclose genetic data to law enforcement only with a warrant or other valid legal process.
  • Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this Policy. Genetic data and text-message opt-in data and consent are never transferred in a sale, merger, or bankruptcy without your express consent.
  • With your consent — for any other purpose you authorize.

6. Genetic Information

  • We process genetic data only with your separate, express consent, which we ask for before any genetic test is ordered or any DNA file is processed, and only to create your genetic report and personalized insights. We do not use it for research or advertising.
  • We never sell genetic data, and we never disclose it to any health, life, long-term care, or disability insurer, any employer, or anyone who advises them.
  • Your DNA sample goes from our kit partner, PromicsEdge, directly to the testing laboratory, Gene by Gene (Houston, Texas; a CLIA-certified, CAP-accredited lab). CellThrive never receives or holds your sample, and the laboratory's own policy also applies. You may ask us at any time to delete your genetic data. We will delete the genetic data in our live systems within 30 days (backup copies within six months) and ask the laboratory to delete your data and destroy your sample. Exercising these rights never changes your price or service.

7. Cookies, Analytics & Advertising

We use cookies and similar technologies to operate the site and to understand how it is used, through our own first-party analytics. Our site also loads tools from our login provider, website host, content-delivery network, and font provider, which receive your IP address and browser information in order to deliver those features. We do not allow third parties to collect your health data over time and across different websites. We never share health information with advertising or analytics networks. We do not use your personal data to train large language models. You can control cookies through your browser.

Text Messages (SMS)

If you opt in to text messages from CellThrive (Framework Wellness LLC), we use your mobile number only to send the messages you agreed to receive. Message frequency varies. Message and data rates may apply. Reply STOP to any message to opt out, HELP for help, or email support@cellthrive.health. We do not sell, rent, or share your mobile number or your text-messaging opt-in data and consent with third parties or affiliates for marketing or promotional purposes; we share them only with the service providers that deliver our messages on our behalf. Text-messaging opt-in data and consent are excluded from all other sharing described in this Policy.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect your information, including encryption of data in transit and at rest and access controls that limit health information to authorized personnel. No method of transmission or storage is completely secure, but we work to protect your information and review our safeguards over time.

9. Data Retention & Deletion

We retain your information for as long as your account is active and as needed to provide the Services, and thereafter as required to meet legal, recordkeeping, tax, and regulatory obligations. When information is no longer needed, we delete or de-identify it. You may request deletion as described below; we will honor such requests except where we are required or permitted by law to retain certain records.

10. Your Privacy Rights

Depending on where you live, you may have the right to confirm whether we hold your consumer health data and access it (including a list of the third parties we have shared it with and how to contact them), correct it, delete it, receive a portable copy, and withdraw consent to its collection or sharing. These rights include those under the Washington My Health My Data Act and Nevada and Connecticut law. To exercise any right, use your account (Account → Your data) or our request form at cellthrive.health/privacy-request. Requests are at no charge up to twice a year. We will verify your identity and respond within 45 days of receiving your request; if we need more time, we will tell you why within those 45 days and may extend once by another 45 days. We delete your data from our live systems within 30 days of receiving your request, and never later than 45 days (backup copies within six months), and tell everyone we shared your data with to delete it. If we decline your request, you may appeal: use the same form and choose "Appeal a decision". We will answer your appeal in writing within 45 days and, if we deny it, tell you how to contact your state Attorney General. You will not be discriminated against for exercising your rights.

11. Health Information & HIPAA

CellThrive is not a HIPAA-covered entity, and HIPAA does not apply to the information you give us. Your information is protected by this Policy, the FTC Act, the FTC Health Breach Notification Rule, and applicable state health-privacy laws.

12. Breach Notification

Email is our primary way of contacting you. If there is a breach of security involving your health information, including any sharing we did not disclose to you, we will notify you without unreasonable delay and no later than 60 calendar days after we discover it, by email together with a text message or a notice in your member portal. We will also notify the Federal Trade Commission and, where required, the media and state authorities.

13. Children's Privacy

Our Services are intended for adults 18 and older. We do not knowingly collect information from anyone under 18. If you believe a minor has provided us information, contact us and we will delete it.

14. Third-Party Links

Our site may link to third-party websites and services we do not control. This Policy does not apply to them; please review their privacy practices.

15. Changes to This Policy

We may update this Policy from time to time and will revise the "Last updated" date when we do. For a material change — including any new way of using or sharing your health information — we will email you at the address on your account no fewer than 7 and no more than 30 days before the change takes effect. We will not use or share health information we already hold in a materially different way without your express consent.

16. Contact Us

For privacy requests, use your account (Account → Your data) or our request form at cellthrive.health/privacy-request. For any other privacy question, or to reach our privacy contact: Framework Wellness LLC (CellThrive), 5830 34th St. N, Birmingham, AL 35207. Email: support@cellthrive.health.