Privacy Policy

The American Academy of Functional Health (“AAFH”) respects your privacy and has designed this practitioner directory with data minimization as a core principle.

The Directory is operated by AAFH and may be technologically supported by iCare Digital Health Solutions LLC.

The Directory primarily serves visitors and practitioners throughout the United States and Canada, including major metropolitan areas and other communities, and may also include practitioners or visitors located in other countries.

This Privacy Policy explains what information may be processed when you use the practitioner directory, how that information may be used, when third-party technologies may process information, and the privacy choices that may be available to you.

For purposes of this Privacy Policy, “Directory” includes the public practitioner-search website and related pages operated by or on behalf of AAFH.

1. Our Privacy Approach

The Directory is designed to allow visitors to locate healthcare practitioners without creating a visitor or patient account and without providing directly identifying information to AAFH.

You do not need to provide AAFH with your:

• name;
• email address;
• telephone number;
• mailing address;
• date of birth;
• medical records;
• laboratory reports;
• insurance information;
• Social Security number;
• payment information; or
• other directly identifying patient information

in order to browse or search the Directory.

The Directory does not create a patient account merely because you conduct a search.

AAFH does not intentionally create patient medical records from Directory searches.

AAFH does not maintain a list identifying individual people who searched for a particular practitioner.

AAFH does not sell lists of Directory visitors to practitioners.

AAFH does not provide a practitioner with your name, email address, telephone number, medical records, or other identifying patient information merely because you viewed that practitioner's profile.

When you choose a practitioner, the Directory may display the practitioner's professional contact information or link you to the practitioner's independent website, scheduling system, clinic, telephone number, or other external service.

Information you subsequently provide directly to that practitioner or external service is not collected or controlled by AAFH through the public Directory.

2. Information That May Be Processed Automatically

Although the Directory does not require you to identify yourself, limited technical information may be processed automatically when you access or use the website.

Depending upon the website configuration and technologies enabled, this may include:

• Internet Protocol (“IP”) address;
• approximate location derived from an IP address;
• browser type and version;
• device type;
• operating system;
• referring website or source;
• pages requested or viewed;
• date and time of access;
• session activity;
• cookie identifiers;
• advertising identifiers;
• campaign or referral information;
• basic interactions with the website;
• security signals;
• technical performance information; and
• other information reasonably necessary to operate, secure, measure, or improve the website.

Some of this information may constitute “personal information,” “personal data,” “personal information about an identifiable individual,” “consumer health data,” or another protected category under applicable privacy law even though AAFH does not know your name.

AAFH seeks to minimize the amount of technical information it retains directly.

Third-party technology providers may process information according to their own systems, contractual arrangements, privacy practices, and applicable law.

3. Approximate Location and Finding Nearby Practitioners

One of the primary purposes of the Directory is to help visitors locate practitioners in their area.

The website may process an IP address or similar technical information to estimate a visitor's approximate geographic location.

This may include an approximate:

• country;
• state;
• province;
• region;
• city;
• postal area; or
• general geographic area.

The estimated location may be used to determine which practitioners are geographically closest or otherwise relevant to the visitor.

Approximate IP-based location may be inaccurate.

Unless a visitor expressly activates a feature requiring more precise device location, the Directory does not require precise GPS location to perform an ordinary practitioner search.

AAFH does not intend to use IP-based location information to:

• maintain a history of your physical movements;
• continuously track your location;
• identify you as a particular patient;
• provide practitioners with your location history; or
• sell a record of your physical movements to data brokers.

Limited location or geographic information may nevertheless be processed by analytics, advertising, security, hosting, geolocation, or other technology providers as described in this Policy.

4. Directory Searches and Health-Related Searches

Visitors may search or filter practitioners based upon location, practitioner characteristics, training, professional focus, services, telehealth availability, specialty areas, clinical interests, or other Directory categories.

A visitor's search for a practitioner associated with a symptom, condition, specialty, treatment area, or health topic does not establish that the visitor personally has that condition or diagnosis.

AAFH does not diagnose users based upon Directory searches.

AAFH does not intentionally create an electronic health record or individualized patient medical profile from ordinary Directory search activity.

AAFH does not sell a visitor's health-related Directory search history to listed practitioners.

Because third-party advertising, analytics, and measurement technologies may operate on portions of the website, technical information concerning website visits may be processed by those providers as described below.

AAFH intends to avoid intentionally transmitting medical records, laboratory results, prescription information, detailed medical histories, or other detailed clinical records to advertising platforms.

Where reasonably practicable, AAFH also seeks to avoid configuring advertising technologies to transmit detailed health-condition search terms or similarly sensitive health-search criteria for behavioral advertising purposes.

5. No Patient Account or Medical Record Created

Visitors do not need to establish an account to browse or search the public Directory.

The public Directory is not intended to function as:

• an electronic health record;
• a patient portal;
• a medical-record repository;
• a telehealth treatment platform;
• a healthcare intake system;
• a medical messaging system; or
• an insurance or billing platform.

Ordinary use of the Directory does not establish a clinician-patient relationship with AAFH or iCare Digital Health Solutions LLC.

6. No Visitor Contact Information Required by the Directory

The public practitioner-search functionality is not designed to require visitors to submit their name, email address, telephone number, medical history, or other directly identifying patient information to AAFH.

Instead, when a visitor chooses a practitioner, the Directory may:

• display the practitioner's telephone number;
• display the practitioner's professional email address;
• display the practitioner's clinic address;
• display the practitioner's website;
• provide an external scheduling link;
• provide an external contact link; or
• transfer the visitor to another website or service controlled by the practitioner or another third party.

Once you leave the Directory and provide information to another organization, that information is governed by the privacy practices of the recipient.

AAFH does not control information that you voluntarily provide directly to an independent practitioner, clinic, scheduling platform, patient portal, or other external provider.

7. Communications With Practitioners

Listed practitioners are independent professionals.

When you contact a practitioner using a telephone number, email address, website, scheduling link, clinic website, patient portal, telehealth system, or other external service, your communication is between you and the practitioner or applicable third party.

AAFH and iCare Digital Health Solutions LLC do not control how an independent practitioner:

• collects personal information;
• obtains medical histories;
• stores medical records;
• uses patient information;
• communicates with patients;
• processes payments;
• manages scheduling;
• uses marketing technologies; or
• complies with healthcare privacy laws.

You should review the practitioner's privacy practices before submitting sensitive personal or medical information.

8. Practitioner Information

The Directory contains professional information concerning participating practitioners.

This may include:

• practitioner name;
• professional degrees or credentials;
• AAFH training or certification information;
• professional photograph;
• clinic or practice name;
• professional biography;
• professional areas of focus;
• practice address;
• telephone number;
• professional email address;
• website;
• scheduling information;
• telehealth availability; and
• other professional or practice-related information.

Practitioners generally provide, authorize, or otherwise permit publication of their Directory information.

AAFH may also maintain or verify certain certification, educational, or program-completion information through its own records.

Practitioners may be located in the United States, Canada, or other jurisdictions.

Practitioners are independently responsible for ensuring that the professional information they provide and their subsequent handling of patient information comply with applicable law.

9. Cookies, Pixels and Similar Technologies

The Directory may use cookies, pixels, tags, scripts, browser storage, advertising identifiers, and similar technologies.

These technologies may support:

• website functionality;
• security;
• fraud and abuse prevention;
• approximate location functionality;
• user preferences;
• technical performance;
• analytics;
• advertising attribution;
• advertising campaign measurement;
• audience creation;
• marketing optimization; and
• retargeting or remarketing.

Some technologies may be operated by third parties, including advertising, analytics, hosting, security, geolocation, and infrastructure providers.

Additional details are provided in the Directory's Cookie Policy.

10. Analytics, Advertising Measurement and Retargeting

AAFH may use analytics, advertising, measurement, and retargeting technologies provided by third parties.

These may include technologies provided by companies such as Google and Meta/Facebook.

Depending upon the services enabled, these technologies may process information such as:

• IP address;
• browser and device information;
• cookie identifiers;
• advertising identifiers;
• approximate geographic area;
• page views;
• referral information;
• website interactions;
• campaign source;
• advertisement interactions;
• session activity; and
• conversion or attribution information.

These technologies may be used to:

• understand general website usage;
• determine how visitors reached the Directory;
• measure advertising performance;
• evaluate campaign effectiveness;
• measure conversions;
• create advertising audiences;
• optimize advertising campaigns;
• exclude audiences where appropriate; and
• advertise to people who previously visited the Directory.

AAFH may therefore be able to retarget an audience of previous visitors without knowing the individual visitor's name, email address, telephone number, or patient identity.

Third-party advertising companies may separately possess information associated with their own accounts, browsers, devices, or platforms. Their processing is governed by their own privacy practices and applicable law.

11. How We Use Limited Information

Information processed in connection with the Directory may be used to:

• operate the website;
• provide practitioner search results;
• identify geographically relevant practitioners;
• maintain website functionality;
• maintain security;
• detect fraud and abuse;
• prevent malicious activity;
• diagnose technical problems;
• monitor website performance;
• analyze aggregate website usage;
• understand traffic sources;
• measure advertising effectiveness;
• attribute visits or conversions to advertising campaigns;
• create advertising or remarketing audiences;
• optimize advertising campaigns;
• improve Directory functionality;
• administer practitioner listings;
• comply with applicable law;
• enforce our Terms of Use; and
• protect the rights, safety, security, and property of AAFH, visitors, practitioners, service providers, and others.

AAFH does not use ordinary Directory searches to create clinical diagnoses or patient medical records.

12. Sale, Sharing and Targeted Advertising

AAFH does not sell visitor names, email addresses, telephone numbers, medical records, or other directly identifying patient information collected through ordinary Directory searches, because the Directory is not designed to collect those items from visitors.

AAFH does not sell lists identifying individual people who searched for specific practitioners.

However, AAFH may use Google, Meta/Facebook, and other advertising or measurement technologies as described in this Privacy Policy.

Those technologies may involve disclosure or processing of online identifiers, IP addresses, browser/device information, page activity, and related technical information.

Under certain privacy laws, disclosure of such information for advertising purposes may legally constitute:

• “sharing”;
• targeted advertising;
• cross-context behavioral advertising; or
• another regulated form of processing,

even where AAFH receives no direct monetary payment for the information and does not know the visitor's identity.

Where applicable law provides a right to opt out of such activity, AAFH will provide or honor applicable privacy controls as required.

13. Advertising and Sensitive Health-Related Information

AAFH may advertise the Directory or related AAFH services using platforms such as Google and Meta/Facebook.

We recognize that the Directory operates in a healthcare-related context.

AAFH does not intentionally provide advertising platforms with:

• patient medical records;
• laboratory reports;
• prescriptions;
• insurance records;
• detailed medical histories; or
• information intentionally identifying an individual as having a particular diagnosis solely because that individual browsed the Directory.

Where reasonably practicable, advertising technologies should be configured so that detailed health-condition search terms, symptom searches, or similarly sensitive Directory search criteria are not intentionally used for behavioral advertising.

Visitors should nevertheless understand that third-party advertising technologies may receive technical information about a visit to a webpage on which those technologies are active.

AAFH does not control the independent information that Google, Meta, or another advertising provider may already possess about a user through that provider's own services.

14. Third-Party Service Providers

AAFH may rely upon third-party companies to operate, secure, measure, advertise, or support the Directory.

These may include providers supporting:

• website hosting;
• cloud infrastructure;
• databases;
• domain services;
• content delivery;
• cybersecurity;
• error monitoring;
• fraud prevention;
• IP-based geolocation;
• mapping;
• website analytics;
• advertising;
• advertising attribution;
• campaign measurement;
• audience creation;
• retargeting or remarketing;
• website performance; and
• other technical operations.

Examples may include Google, Meta/Facebook, hosting providers, cloud providers, geolocation providers, analytics providers, and other infrastructure or technology companies.

These providers may process technical or online information when providing their services.

Use of a service provider does not necessarily constitute a “sale” of information. However, particular advertising-related disclosures may constitute “sharing” or targeted advertising under applicable privacy law.

15. Disclosure Required by Law

AAFH may disclose information where reasonably necessary to:

• comply with applicable law;
• respond to valid legal process;
• comply with subpoenas or court orders;
• respond to lawful government requests;
• investigate fraud or abuse;
• protect website security;
• enforce agreements;
• defend legal claims;
• protect the rights or property of AAFH or others; or
• prevent or respond to threats of harm.

Nothing in this Privacy Policy limits disclosures that are lawfully required.

16. Business Transfers

If AAFH, the Directory, or relevant assets are involved in a merger, acquisition, restructuring, financing, reorganization, sale, transfer, or similar transaction, information associated with operation of the Directory may be transferred as part of that transaction, subject to applicable law.

Because the Directory is designed to minimize directly identifying visitor information, AAFH expects the amount of directly identifiable visitor information maintained by the Directory itself to be limited.

17. Data Retention

AAFH follows a data-minimization approach.

AAFH does not intentionally maintain persistent patient profiles containing visitor names, email addresses, medical histories, or clinical records based upon ordinary public Directory searches.

Approximate IP-derived location is used to support geographic functionality and is not intended to become a persistent AAFH record of an identified visitor's movements.

Technical information may nevertheless exist temporarily or for reasonable operational periods in:

• server logs;
• security logs;
• hosting infrastructure;
• analytics systems;
• advertising platforms;
• cookie systems;
• geolocation services; or
• other technical systems.

Third-party providers establish their own retention periods according to their products, configurations, contracts, policies, and legal obligations.

AAFH retains information under its direct control only for as long as reasonably necessary for applicable operational, security, administrative, legal, or regulatory purposes.

18. Data Security

AAFH uses reasonable administrative, technical, and organizational safeguards intended to protect information associated with operation of the Directory.

However, no website, network, Internet transmission, advertising technology, database, or electronic storage system can be guaranteed to be completely secure.

Because the public Directory is not intended to receive medical records or sensitive patient information, visitors should not attempt to submit such information through general public website functionality.

19. HIPAA and Other Healthcare Privacy Laws

The public practitioner Directory is not intended to collect, store, or maintain patient medical records.

Use of the Directory alone does not create a clinician-patient relationship.

AAFH's operation of the public Directory does not, by itself, mean that technical information processed through the website constitutes Protected Health Information under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”).

A listed practitioner's independent practice may separately be subject to:

• HIPAA;
• state health-information laws;
• Canadian federal privacy law;
• Canadian provincial health-information laws; or
• other national, provincial, territorial, state, or regional healthcare privacy laws.

The independent practitioner or healthcare organization is responsible for complying with laws applicable to information it receives directly from patients.

20. Consumer Health Information

Certain U.S. states have laws specifically regulating consumer health information outside traditional HIPAA-covered settings.

Because the Directory relates to healthcare practitioners, certain browsing activity or search selections could potentially fall within broad statutory definitions of consumer health information depending upon applicable law and the surrounding circumstances.

The Directory is therefore designed not to require visitors to provide:

• diagnoses;
• medical records;
• treatment histories;
• prescription histories;
• laboratory reports;
• reproductive-health records;
• biometric health records; or
• detailed individualized medical histories

in order to search for a practitioner.

A visitor's search for a health-related practitioner or topic does not establish that the visitor has the corresponding condition.

AAFH does not intentionally sell detailed consumer health information collected through Directory searches.

AAFH does not intentionally maintain an individualized clinical profile from ordinary Directory searches.

Where applicable law provides additional rights concerning consumer health information, AAFH will address those rights as required.

21. Children's Privacy

The Directory is intended primarily for adults seeking information concerning healthcare practitioners.

The Directory is not directed toward children under 13.

AAFH does not knowingly solicit directly identifying personal information from children under 13 through ordinary public Directory searches.

Parents or guardians seeking practitioners for children should generally conduct Directory searches on the child's behalf.

We do not intentionally use the Directory to create behavioral advertising profiles about known children.

22. Privacy Rights by Jurisdiction

Depending upon where you reside and whether a particular law applies to AAFH, you may have rights concerning personal information.

These may include rights to:

• know or access certain personal information;
• request correction;
• request deletion;
• obtain certain information in portable form;
• withdraw consent where applicable;
• object to certain processing;
• restrict certain processing;
• opt out of targeted advertising;
• opt out of certain sales or sharing;
• limit certain uses of sensitive information;
• appeal certain privacy decisions; or
• submit a complaint to an applicable privacy authority.

The availability and scope of these rights vary by jurisdiction and may be subject to statutory exceptions.

Because AAFH does not require visitors to identify themselves to use the Directory, AAFH may have little or no directly identifying information associated with a particular visitor.

We will not intentionally require a person to submit unnecessary medical or other sensitive information merely to exercise a privacy right.

23. United States Privacy Rights

Residents of certain U.S. states may have privacy rights under applicable state privacy laws.

Depending upon applicable law, these may include rights concerning:

• access;
• correction;
• deletion;
• portability;
• sale;
• sharing;
• targeted advertising;
• profiling;
• sensitive information; and
• recognized universal opt-out mechanisms.

AAFH does not sell directly identifying visitor information collected through ordinary Directory searches.

AAFH may, however, use advertising and retargeting technologies that process online identifiers and website activity.

Where applicable state law characterizes such processing as targeted advertising, sale, sharing, or another activity subject to an opt-out right, AAFH will provide or honor the applicable rights as required.

24. California Residents

If the California Consumer Privacy Act (“CCPA”), as amended, applies to AAFH, eligible California residents may have rights relating to personal information.

These may include rights to:

• know;
• access;
• delete;
• correct;
• opt out of sale;
• opt out of sharing for cross-context behavioral advertising;
• limit certain uses or disclosures of sensitive personal information where applicable; and
• exercise rights without unlawful discrimination.

AAFH does not sell visitor names, emails, telephone numbers, or medical records collected through ordinary Directory searches.

However, use of third-party advertising and retargeting technologies may involve disclosures that qualify as “sharing” for cross-context behavioral advertising under California law.

Where required, visitors may exercise applicable opt-out rights through a Your Privacy Choices, Do Not Sell or Share My Personal Information, cookie-preference, or similar mechanism.

Where legally required, AAFH will also honor applicable user-enabled opt-out preference signals, including Global Privacy Control (“GPC”).

AAFH will not require a visitor to create an account merely to exercise an applicable opt-out right.

25. Canadian Privacy

The Directory serves visitors and practitioners throughout Canada as well as the United States.

Depending upon the circumstances, Canadian federal or provincial privacy laws may apply to certain processing.

This may include the Personal Information Protection and Electronic Documents Act (“PIPEDA”), where applicable, and provincial privacy legislation.

AAFH's approach to Directory privacy incorporates principles of:

• data minimization;
• limited collection;
• identified purposes;
• reasonable use;
• transparency;
• appropriate safeguards; and
• user choice where required.

AAFH may use cookies and similar technologies for advertising measurement and retargeting.

Where Canadian law requires consent or another privacy mechanism for particular advertising, tracking, or cookie activity, AAFH will seek to provide appropriate notice and choice.

AAFH does not sell lists identifying individual Canadian visitors who searched for particular practitioners.

Canadian practitioners remain independently responsible for complying with privacy and health-information laws applicable to their professional practices.

26. International Visitors and Cross-Border Processing

The Directory may be accessed from countries outside the United States and Canada.

AAFH operates from the United States and may rely upon technology providers that process information in the United States, Canada, or other jurisdictions.

Accordingly, limited technical information may be transferred to or processed in jurisdictions outside the visitor's place of residence.

Privacy protections, government-access rules, and legal requirements differ by jurisdiction.

Where applicable law imposes additional requirements for cross-border processing or transfers, AAFH will address those obligations where they apply to AAFH's activities.

The fact that the public website can technically be accessed from a particular country does not, by itself, mean that every law of that jurisdiction necessarily applies to AAFH.

27. Your Privacy Choices — Sale, Sharing and Targeted Advertising

AAFH does not sell visitor names, emails, telephone numbers, medical records, or directly identifying patient profiles derived from ordinary Directory searches.

AAFH may nevertheless use third-party advertising and retargeting technologies that process online identifiers and website activity.

Under some privacy laws, these activities may constitute “sharing,” targeted advertising, cross-context behavioral advertising, or another regulated activity.

Where applicable, visitors may be able to exercise privacy choices through:

• a cookie or privacy preference center;
• Your Privacy Choices;
• Do Not Sell or Share My Personal Information;
• browser privacy controls;
• recognized opt-out preference signals;
• Google advertising controls;
• Meta/Facebook advertising controls; or
• other mechanisms provided by applicable law.

Exercising an applicable privacy right should not prevent access to the basic public practitioner Directory except where a particular technology is strictly necessary for website functionality.

28. Global Privacy Control and Browser Signals

Certain browsers and extensions transmit privacy preference signals, including Global Privacy Control.

Where applicable law requires AAFH to recognize a valid opt-out preference signal, AAFH will process that signal as legally required.

Browser settings may also allow users to:

• block cookies;
• delete cookies;
• reject third-party cookies;
• limit cross-site tracking; or
• clear stored website information.

Disabling strictly necessary technologies may impair certain website functions.

29. Third-Party Websites and Practitioner Services

The Directory may link to services operated by independent practitioners or third parties, including:

• practitioner websites;
• scheduling platforms;
• clinic websites;
• patient portals;
• telehealth services;
• maps;
• social-media platforms;
• payment services;
• CRM systems; and
• other external services.

Once you leave the Directory, the external operator's privacy practices apply.

AAFH and iCare Digital Health Solutions LLC are not responsible for the privacy practices, security, data collection, advertising technologies, medical-record practices, or other activities of independent practitioners or third-party websites.

AAFH does not receive information merely because a visitor subsequently provides that information directly to a practitioner.

30. Changes to This Privacy Policy

AAFH may update this Privacy Policy to reflect changes in:

• Directory functionality;
• technology;
• cookies;
• advertising systems;
• analytics;
• retargeting;
• service providers;
• privacy practices;
• applicable laws; or
• regulatory requirements.

The “Last Updated” date at the top of this Policy identifies the most recent revision.

Material changes will be communicated where required by applicable law.

31. Contacting Us About Privacy

Questions concerning this Privacy Policy, privacy practices associated with the Directory, or applicable privacy requests may be directed to:

American Academy of Functional Health

Email: Operations@TheAAFH.org

Privacy requests should include sufficient information for us to understand the request.

Because visitors are not required to establish accounts or identify themselves to search the Directory, we may have little or no information that allows us to associate anonymous or pseudonymous website activity with a particular individual.

We will not request unnecessary medical or other sensitive information merely to process a privacy inquiry.

If your question relates to information provided directly to a practitioner, clinic, scheduling platform, healthcare provider, or other external service, please contact that organization directly.

32. Relationship to Other Policies

This Privacy Policy should be read together with the Directory's:

• Terms of Use; and
• Cookie Policy.

The Cookie Policy contains additional information regarding cookies, Meta/Facebook technologies, Google technologies, analytics, advertising measurement, and retargeting.

If you leave the Directory and access a practitioner's website, scheduling system, patient portal, telehealth platform, or another external service, the privacy policy and terms of that independent service apply.