POWERED BY WALNUT HILL MEDICAL

Privacy Policy

 

Effective Date: October 11, 2026
Last Updated: October 19, 2026

#1. Introduction

WHM Academy (“WHM Academy,” “we,” “our,” or “us”) respects your privacy and is committed to protecting the personal information you share with us.

This Privacy Policy explains how we collect, use, disclose, store, and protect personal information when you visit our website, access our resources, purchase our products, subscribe to our communications, join a waitlist, or otherwise interact with our services.

WHM Academy serves two primary audiences:

  • MedTech Innovators: Individuals, founders, entrepreneurs, researchers, and organizations interested in developing, commercializing, and building medical device businesses, including visitors interested in our *Built to Exit* book and related commercialization resources.
  • Patients & Caregivers: Individuals and families interested in resources such as *It's Not Over* and related educational materials.

This Privacy Policy applies to both audience paths and to all website pages, forms, landing pages, checkout experiences, email communications, and other services that link to or reference this policy.

By using our website, you acknowledge that you have had the opportunity to read this Privacy Policy. Where applicable law requires consent for a particular processing activity, we will seek that consent separately. Simply visiting our website does not constitute consent to activities for which consent is legally required.

Please read this policy carefully to understand our privacy practices and the choices available to you.

# 2. Who We Are

WHM Academy provides educational resources and information intended to help medical device innovators and other audiences access relevant educational materials.

Our website may include:

  • Information about WHM Academy and its educational resources.
  • Book descriptions, sales pages, and purchasing options.
  • Free downloads, including the *Built to Exit* commercialization checklist.
  • Email subscriptions and educational follow-up communications.
  • Waitlist registration for *It's Not Over* and other forthcoming resources.
  • Future educational products, courses, communities, or related services as they become available.

Website: whmacademy.com

Legal Entity Name: Walnut Hill Medical, LLC

Business Mailing Address: 8350 N. Central Expy., , Suite 1900, PMB #3349 • Dallas, Texas • 75206

Privacy Contact Email: [email protected]

For questions about this policy, your personal information, or a privacy request, contact us using the details above.

In this policy, “personal information” and “personal data” mean information that identifies, relates to, describes, or could reasonably be linked to an identifiable individual, as defined under applicable privacy law.

# 3. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through:

  1. Our official website and its subpages.
  2. Audience-specific landing pages for MedTech Innovators and Patients & Caregivers.
  3. Forms used to request free resources or subscribe to email communications.
  4. Waitlist forms and announcements for forthcoming books or other products.
  5. Checkout, payment, order confirmation, and product delivery processes.
  6. Customer service inquiries and communications with our team.
  7.  Email marketing and other communications we send.
  8. Website cookies and similar technologies, where used.
  9. Other digital interactions that link to this Privacy Policy.

This policy does not automatically apply to third-party websites, payment services, online platforms, or other services that we do not control. Those services may have their own privacy policies.

# 4. Personal Information We Collect

The information we collect depends on how you interact with WHM Academy. We aim to collect information that is reasonably necessary for the relevant purpose.

# 4.1 Information You Provide Directly

You may provide personal information when you complete a form, purchase a product, subscribe to emails, join a waitlist, or contact us.

Depending on the interaction, this information may include:

  • First and last name.
  • Email address.
  • Telephone number, if requested.
  • Billing address.
  • Shipping address for physical products.
  • Organization, company, or professional affiliation.
  • Information you voluntarily include in a message or inquiry.
  • Product selection, order details, and communication preferences.
  • Waitlist registration details.
  • Consent and subscription preferences.
  • Other information specifically requested in a form and reasonably necessary for its stated purpose.

You are not required to provide information that is not necessary to complete your requested interaction, except where a particular field is genuinely required to provide the service.

Please do not submit confidential medical records, detailed health histories, financial account credentials, or other sensitive information through general website forms unless we expressly provide an appropriate channel and explain how the information will be handled.

# 4.2 Information Collected When You Request a Free Resource

If you request a free resource, such as the *Built to Exit* checklist, we may collect your name and email address and any other information explicitly requested by the form.

We use this information to:

  • Process your request.
  • Send or provide access to the requested resource.
  • Maintain records of the request.
  • Send related follow-up or educational emails where permitted by law and consistent with your preferences and the notices presented at signup.
  • Understand which educational resources are relevant to our audiences.
  • Maintain the accuracy and security of our contact records.

Requesting a resource does not automatically authorize every form of marketing communication. Where separate consent is required, we will obtain it.

# 4.3 Information Collected Through the MedTech Innovators Path

Visitors interested in Medtech Innovators resources may request the *Built to Exit* checklist, explore the *Built to Exit* book, or purchase related products.

We may collect information necessary to provide these services, including:

  • Contact information.
  • Resource request and download records.
  • Book purchase and order details.
  • Billing and shipping information, as applicable.
  • Email subscription and communication preferences.
  • Records of communications relating to orders or requested resources.

We may use this information to provide requested materials, fulfill orders, deliver customer service, and send relevant educational or promotional communications where permitted.

The subject matter of an educational resource does not mean we intend to collect confidential information about your medical device, intellectual property, clinical research, or business plans. Please do not submit confidential business or technical information through general contact forms.

# 4.4 Information Collected Through the Patients & Caregivers Path

Visitors interested in *It's Not Over* or other Patients & Caregivers resources may be able to join a waitlist or request updates.

If you join a waitlist, we may collect:

  • Your name, if requested.
  • Your email address.
  • Your registration date.
  • Your waitlist status.
  • Your communication and consent preferences.
  • Records of messages or updates sent to you.

We use this information to manage the waitlist, communicate relevant availability or release updates, and provide information about the requested resource.

Joining a waitlist does not constitute a purchase or guarantee a release date, product availability, or access to future services. Any separate purchase terms or commitments will be communicated at the relevant time.

We do not need detailed medical information to operate a general book waitlist. Please do not include diagnoses, treatment details, medical records, or other sensitive health information in a waitlist form or email unless we expressly request it through an appropriate process.

# 4.5 Purchase and Transaction Information

If you purchase a book or another product through our website, we or our relevant service providers may process information necessary to complete the transaction.

This may include:

  • Customer name and contact information.
  • Billing and shipping addresses.
  • Products purchased.
  • Order number and transaction date.
  • Order status and fulfillment details.
  • Payment status and transaction references.
  • Refund, cancellation, or customer support records.
  • Relevant tax or accounting information.

Payments may be processed by an external payment provider. Depending on the payment method and service used, that provider may collect and process payment card details or other financial information directly.

We do not intend to store complete payment card numbers or card security codes on our own systems. The actual payment-handling arrangement will depend on the provider integrated with our checkout.

Payment providers may process information under their own privacy notices and terms.

# 4.6 Information You Provide When Contacting Us

If you contact WHM Academy by email, through a contact form, or by another supported method, we may collect your contact details, the content of your message, attachments you choose to send, and our subsequent correspondence.

We use this information to respond to inquiries, address customer concerns, provide support, and maintain appropriate business records.

Please avoid sending sensitive personal information or confidential documents unless they are necessary for your inquiry and you have an appropriate reason to share them.

# 4.7 Information Collected Automatically

When you visit our website, certain technical information may be collected automatically by our website platform, hosting provider, security services, or other integrated tools.

Depending on the services enabled, this information may include:

  • Internet Protocol (IP) address.
  • Browser type and version.
  • Device type and operating system.
  • Language settings.
  • Referring website or page.
  • Pages visited and links clicked.
  • Date, time, and duration of visits.
  • Approximate location inferred from an IP address.
  • Technical error and diagnostic information.
  • Cookie identifiers and similar online identifiers.

We may use this information to operate the website, maintain security, troubleshoot errors, understand website performance, and improve usability.

The information actually collected depends on the technical configuration of our website and its service providers.

# 4.8 Cookies and Similar Technologies

Our website may use cookies, pixels, scripts, local storage, or similar technologies.

These technologies may be used for:

  • Essential functions: Supporting website operation, security, form submission, checkout, and session management.
  • Preferences: Remembering settings or choices.
  • Analytics: Understanding how visitors interact with the website and measuring website performance.
  • Marketing: Measuring campaigns or advertising effectiveness, where applicable.

The specific technologies in use will depend on the services enabled on our website.

Where applicable law requires consent for non-essential cookies or similar technologies, we will provide an appropriate consent mechanism before using them. You may be able to change your choices through our cookie settings or your browser settings.

Blocking certain cookies may affect the operation of some website features.

For more information, see the “Cookies and Similar Technologies” section below.

# 5. How We Use Personal Information

We may use personal information for the following purposes, as applicable to your interaction with us.

# 5.1 To Provide Requested Products and Resources

We use relevant information to:

  • Process requests for free resources.
  • Provide access to requested downloads.
  • Process and confirm purchases.
  • Coordinate physical product fulfillment and shipping.
  • Provide access to purchased digital products.
  • Manage waitlists and requested product updates.
  • Respond to customer service requests.

# 5.2 To Send Transactional and Service Communications

We may send communications necessary to complete or support a transaction or service, including:

  • Order confirmations and receipts.
  • Payment or order-status notifications.
  • Digital product access information.
  • Shipping and fulfillment updates.
  • Responses to inquiries.
  • Important changes to a service or its terms.

These communications are distinct from general promotional emails. Where permitted by law, essential transactional communications may continue even if you unsubscribe from marketing emails.

# 5.3 To Send Educational and Promotional Emails

Where permitted by applicable law, we may use your contact information to send relevant educational content, product information, book announcements, and promotional communications.

For example, someone who requests the Built to Exit checklist may receive related educational follow-up emails about commercialization strategy and the Built to Exit book, subject to the applicable signup notice, consent requirements, and communication preferences.

Someone who joins the It's Not Over waitlist may receive updates related to that book or the requested resource.

We seek to keep communications relevant to the audience path and resource with which you interacted.

You can unsubscribe from marketing emails at any time using the unsubscribe link in the message or by contacting us.

Unsubscribing from marketing does not necessarily stop transactional or legally required communications.

# 5.4 To Manage Our Website and Business

We may use information to:

  • Maintain and improve website functionality.
  • Diagnose technical issues.
  • Monitor performance and reliability.
  • Protect against spam, abuse, fraud, and unauthorized activity.
  • Maintain appropriate business and accounting records.
  • Manage subscriptions and customer relationships.
  • Evaluate the usefulness of our resources.
  • Understand aggregate patterns in website usage.
  • Enforce our terms and protect our legal rights.

# 5.5 To Comply With Legal Obligations

We may process and retain information when reasonably necessary to comply with applicable laws, tax and accounting requirements, lawful requests, court orders, regulatory obligations, or other legal processes.

# 5.6 To Protect Rights, Safety, and Security

We may use or disclose information when reasonably necessary to investigate suspected fraud, address security incidents, enforce applicable terms, protect WHM Academy or other persons, or establish, exercise, or defend legal claims.

# 6. Legal Bases for Processing Where Required

For individuals protected by privacy laws that require a legal basis for processing, we rely on one or more applicable legal grounds depending on the circumstances.

These may include:

Consent: Where you have given valid consent for a particular purpose, such as certain marketing communications or non-essential cookies.

Contractual necessity: Where processing is necessary to take steps at your request or fulfill an agreement, such as processing an order or providing a purchased product.

Legitimate interests: Where processing is necessary for legitimate business purposes, such as maintaining website security, preventing abuse, responding to inquiries, or improving our services, provided those interests are not overridden by your rights and freedoms.

Legal obligation: Where processing is necessary to comply with applicable law.

Vital interests or other lawful grounds: Where recognized by applicable law and relevant to the circumstances.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

The legal basis available to us depends on the applicable law and the specific processing activity. We do not rely on a single legal basis for every activity.

# 7. How We Share Personal Information

We do not need to disclose personal information to unrelated third parties merely because you visit our website. However, certain information may be shared where necessary to provide our services, operate our business, or comply with the law.

# 7.1 Service Providers and Processors

We may share relevant information with service providers that perform functions on our behalf.

Depending on our actual integrations, these providers may include:

  • Website hosting and website platform providers.
  • Form and landing-page providers.
  • Email delivery and marketing platforms.
  • Payment processing providers.
  • E-commerce and order management providers.
  • Digital product delivery services.
  • Physical product fulfillment and shipping providers.
  • Website analytics providers.
  • Security, fraud prevention, and spam prevention services.
  • Customer support and business administration tools.

These providers may process information as necessary to provide their services to us, subject to the applicable contractual arrangements and laws.

We will update this policy or provide additional disclosures if our data-sharing practices materially change.

# 7.2 Payment and Fulfillment Providers

When you make a purchase, relevant transaction details may be shared with payment processors, fulfillment services, shipping providers, and other parties necessary to complete the order.

For example, a shipping provider may need your name and delivery address to deliver a physical book.

These parties may also process certain information to prevent fraud, maintain transaction records, or comply with their legal obligations.

# 7.3 Professional Advisers

We may disclose relevant information to lawyers, accountants, auditors, insurers, or other professional advisers when reasonably necessary to obtain professional services, manage our business, or protect our legal interests.

# 7.4 Legal and Regulatory Disclosures

We may disclose information where we reasonably believe disclosure is necessary to comply with applicable law, a valid legal process, a court order, a lawful government request, or another enforceable obligation.

Where legally permitted and appropriate, we will limit such disclosure to the information reasonably necessary for the stated purpose.

# 7.5 Business Transfers

If WHM Academy or the relevant business is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal information may be disclosed to relevant parties as part of that process, subject to appropriate safeguards and applicable law.

# 7.6 With Your Direction or Consent

We may disclose information when you specifically request or authorize us to do so, or when the disclosure is otherwise permitted by applicable law.

# 7.7 Sale of Personal Information

We will not state that personal information is never sold or shared unless that statement accurately reflects our actual practices and the operation of all relevant third-party tools.

If our activities fall within a legal definition of selling or sharing personal information, including certain sharing for cross-context behavioral advertising, we will provide the notices and choices required by applicable law.

Where required, we will offer a mechanism to opt out of such activities.

# 8. Email Marketing and Communication Preferences

We may use an email platform to manage subscriptions, send requested resources, deliver service messages, and distribute educational or promotional emails.

Our email communications may include information about:

  • Books and educational resources.
  • Related articles or learning materials.
  • Product availability and release announcements.
  • Updates relevant to the resource you requested.
  • Other WHM Academy offerings that we are permitted to promote to you.

# 8.1 Unsubscribing

You may unsubscribe from promotional emails at any time by clicking the unsubscribe link included in the message or contacting us directly.

Once your request has been processed, we will stop sending the relevant promotional communications, subject to any reasonable processing time and legal requirements.

If you subscribe to different types of communications, unsubscribing from one category may not automatically unsubscribe you from every category unless the applicable preference mechanism provides that option.

# 8.2 Transactional Communications

We may continue to send messages directly related to an order, requested service, account, security issue, or legal obligation even after you unsubscribe from promotional emails.

# 8.3 Email Tracking

Depending on the email service and its configuration, we or our providers may use tracking technologies to measure message delivery, email opens, clicks, or other engagement.

We will configure and disclose these practices as required by applicable law. You may be able to limit some tracking through email-client settings or available preference controls.

# 8.4 Accuracy of Contact Information

You are responsible for providing accurate contact information when submitting a form or placing an order. If your email address changes, you may need to update your preferences or contact us to maintain access to relevant communications.

# 9. Cookies and Similar Technologies

Cookies are small files stored on your device by websites. Similar technologies can perform related functions.

# 9.1 Types of Cookies

Depending on the configuration of our website, we may use the following categories:

Strictly necessary cookies: These support essential functions such as security, session management, form operation, or checkout.

Functional cookies: These remember preferences or improve usability.

Analytics cookies: These help measure traffic, page performance, and how visitors use the website.

Advertising or marketing cookies: These may be used to measure advertising campaigns or recognize interactions with marketing content across services.

Not every category will necessarily be active on our website.

# 9.2 Your Cookie Choices

Where required, we will seek your consent before placing non-essential cookies or using similar technologies.

Depending on the available controls, you may be able to:

  • Accept or reject non-essential cookies.
  • Choose specific categories of cookies.
  • Change your preferences later.
  • Delete cookies through your browser.
  • Configure your browser to block certain cookies.

Browser controls alone may not communicate your preferences to every service, and blocking essential cookies may interfere with website functionality.

# 9.3 Third-Party Technologies

Third-party services embedded in or integrated with the website may set or access their own cookies or similar technologies. Their practices are governed by their own policies and applicable legal requirements.

We will make reasonable efforts to identify relevant technologies and configure them in accordance with applicable requirements.

# 9.4 Changes to Cookie Practices

If we introduce new analytics, advertising, or other tracking technologies, we will review whether this policy, our cookie disclosures, or our consent mechanisms need to be updated.

# 10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, unless a longer retention period is required or permitted by law.

The appropriate retention period depends on the type of information, the reason it was collected, the nature of our relationship with you, and any applicable legal obligations.

Examples include:

  • Resource requests: Retained as needed to deliver the resource, administer related communications, and maintain appropriate records.
  • Email subscriptions: Retained while the subscription is active and for a reasonable period afterward to maintain suppression and compliance records.
  • Waitlist registrations: Retained while the waitlist is active and for a reasonable period needed to manage requested updates, resolve inquiries, and maintain relevant records.
  • Purchase and transaction records: Retained as needed for fulfillment, customer support, tax, accounting, fraud prevention, and legal compliance.
  • Customer support messages: Retained for a reasonable period to resolve inquiries and maintain relevant business records.
  • Technical and security logs: Retained for periods appropriate to security, troubleshooting, and operational needs.
  • Consent and unsubscribe records: Retained as reasonably necessary to document preferences and demonstrate compliance.

When information is no longer reasonably necessary, we will delete it, anonymize it, or otherwise dispose of it securely, subject to applicable legal requirements and legitimate recordkeeping needs.

We do not promise a specific deletion deadline unless one is expressly stated and implemented.

# 11. Data Security

We take reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure.

Depending on the systems used, safeguards may include:

  • Access controls and restricted account permissions.
  • Password and account security measures.
  • Secure connections where supported.
  • Security and software updates.
  • Service-provider security controls.
  •  Data minimization and appropriate handling procedures.
  • Monitoring and troubleshooting of technical issues.
  • Appropriate backups and recovery procedures.

No website, email system, online transmission, or electronic storage method can be guaranteed to be completely secure.

We therefore cannot guarantee absolute security, but we aim to use reasonable safeguards appropriate to the nature of the information and the risks involved.

You should also take reasonable steps to protect your email account, devices, and any access credentials associated with services you use.

If a personal data breach occurs, we will assess and respond to it in accordance with applicable legal requirements, including any required notifications.

# 12. International Data Transfers

WHM Academy may use service providers or platforms that store or process information in countries other than the country in which you reside.

As a result, personal information may be transferred internationally, subject to the safeguards and legal requirements that apply to the relevant transfer.

Where required, we will use an appropriate legal transfer mechanism, such as an applicable adequacy decision, approved contractual safeguards, or another lawful mechanism.

The level of data protection in another country may differ from the protection available in your country of residence.

For further information about applicable transfer safeguards, you may contact us using the details in the “Contact Us” section.

# 13. Your Privacy Rights

Depending on where you live and which laws apply, you may have rights regarding your personal information.

These rights may include the following.

# 13.1 Right to Access

You may have the right to request confirmation of whether we process your personal information and to receive a copy of certain information we hold about you.

# 13.2 Right to Correction

You may request that inaccurate or incomplete personal information be corrected.

# 13.3 Right to Deletion

You may request deletion of personal information, subject to legal exceptions and our legitimate need to retain certain records.

For example, we may need to retain specific transaction records to comply with tax, accounting, fraud prevention, or other legal obligations.

# 13.4 Right to Data Portability

Where applicable, you may request certain information in a portable format or ask us to transfer it to another provider where the law provides that right.

# 13.5 Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal will not affect processing that occurred lawfully before the withdrawal.

# 13.6 Right to Object or Restrict Processing

Where applicable, you may object to certain processing activities or request that we restrict processing in specified circumstances.

You may have an unconditional right to object to direct marketing under some privacy laws.

# 13.7 Right to Opt Out of Certain Data Uses

Depending on the law applicable to you and our actual practices, you may have the right to opt out of certain sales of personal information, targeted advertising, or profiling that produces legal or similarly significant effects.

# 13.8 Right to Non-Discrimination

Where required by applicable law, we will not unlawfully discriminate against you for exercising your privacy rights.

# 13.9 Rights Under Specific Laws

Additional rights may apply under laws such as the California Consumer Privacy Act, as amended, the EU General Data Protection Regulation, the UK General Data Protection Regulation, and other applicable privacy laws.

The availability and scope of these rights depend on the law that applies to you and our activities.

# 14. How to Exercise Your Privacy Rights

To submit a privacy request, contact us at:

Email: [email protected]

Subject line: Privacy Rights Request

Please describe the request and provide enough information for us to understand and process it.

We may need to verify your identity before disclosing, correcting, or deleting personal information. We will request only information reasonably necessary for verification and will handle it in accordance with applicable law.

If you authorize another person to submit a request on your behalf, we may need to verify the authorization and the identity of the relevant individuals.

We will respond within the period required by applicable law. If we need additional time or cannot fulfill a request in whole or in part, we will explain the reason where required.

Certain requests may be limited by legal exceptions, including requirements to retain transaction records, protect another person's rights, preserve security, or establish or defend legal claims.

Where applicable law provides a right to appeal a decision concerning a privacy request, you may exercise that right by following the instructions in our response or contacting us again with the subject line “Privacy Request Appeal.”

You may also have the right to lodge a complaint with your relevant data protection authority or privacy regulator.

# 15. California Privacy Disclosures

This section applies to California residents to the extent that the California Consumer Privacy Act, as amended, applies to WHM Academy.

# 15.1 Categories of Personal Information

Depending on your interaction with our website, we may collect information within categories such as:

  • Identifiers, including names, email addresses, IP addresses, and similar identifiers.
  • Customer records, such as billing and shipping details.
  • Commercial information, including products purchased and transaction history.
  • Internet or other electronic network activity, such as website interactions and technical logs.
  • Inferences drawn from information to understand preferences, where applicable.

The categories actually collected depend on our website configuration and the information you provide.

We do not intend to collect every category listed above from every visitor.

# 15.2 Purposes of Collection

We may use relevant information to provide requested resources, process orders, communicate with you, maintain security, improve our services, comply with law, and carry out other purposes described in this policy.

# 15.3 Categories of Recipients

Depending on the information and purpose, we may disclose relevant information to service providers, payment processors, fulfillment providers, professional advisers, legal authorities, and other parties described in the “How We Share Personal Information” section.

# 15.4 Sale and Sharing

We will assess whether our practices constitute a “sale” or “sharing” of personal information under California law, including certain activities involving cross-context behavioral advertising.

If applicable law requires an opt-out mechanism, we will provide it and honor valid opt-out requests.

# 15.5 California Privacy Requests

Eligible California residents may have rights to know, access, delete, correct, and opt out of certain uses of personal information, subject to applicable conditions and exceptions.

To submit a request, email [email protected] with the subject line “California Privacy Request.”

We will verify and process the request in accordance with applicable law.

# 16. European Economic Area, United Kingdom, and Similar Jurisdictions

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with similar privacy protections, additional rights and obligations may apply.

Where applicable, we will provide information about:

  • The identity and contact details of the relevant data controller.
  • The purposes and legal bases for processing.
  • Categories of personal information processed.
  • Recipients or categories of recipients.
  • International transfers and relevant safeguards.
  • Retention periods or the criteria used to determine them.
  • Applicable data subject rights.
  • The right to complain to a supervisory authority.

Where applicable, you may also have the right to withdraw consent, object to certain processing, request restriction, or receive portable information.

If we rely on legitimate interests, you may request further information about those interests, subject to applicable law.

Where required, we will obtain consent before using non-essential cookies or similar technologies.

For privacy inquiries, contact [email protected].

Data Controller: Walnut Hill Medical, LLC

Registered or Business Address: 8350 N. Central Expy., , Suite 1900, PMB #3349 • Dallas, Texas • 75206

Privacy Contact: [email protected]

If a formal data protection representative or other statutory contact is required for our activities, we will provide the relevant details in accordance with applicable law.

# 17. Children's Privacy

WHM Academy's website and educational resources are intended for adults and other audiences appropriate to the content of the relevant resource. We do not knowingly collect personal information from children in circumstances where doing so would violate applicable law.

The Patients & Caregivers section is intended to provide educational information to relevant readers; it is not an invitation for children to submit personal information directly.

If you are a parent or legal guardian and believe a child has provided personal information to us without the required authorization, contact [email protected].

We will review the request and take appropriate action as required by applicable law.

Where a service is directed to children or is subject to special rules governing children's personal information, we will implement any required notices, consent processes, and parental rights.

# 18. Health Information and Educational Disclaimer

WHM Academy may publish educational material concerning medical device innovation, commercialization, or resources intended for patients and caregivers.

However, the existence of such content does not mean that our general website forms are intended to collect protected health information or detailed medical records.

Unless a specific service expressly states otherwise, please do not submit medical records, diagnoses, treatment details, insurance information, or other sensitive health information through general website forms, waitlists, or ordinary email communications.

Information submitted to WHM Academy is not automatically protected by the privacy laws that apply specifically to healthcare providers, health plans, or other regulated entities. The legal protections applicable to information depend on the circumstances and the parties involved.

Our educational content is not a substitute for personalized medical, clinical, legal, regulatory, reimbursement, or other professional advice.

If we introduce a service specifically designed to collect sensitive health information, we will assess the applicable legal and security requirements and provide additional notices or safeguards where required.

# 19. Third-Party Websites and Services

Our website may contain links to third-party websites, payment providers, social media services, or other external resources.

These third parties operate independently and may collect information when you visit their websites or interact with their services.

We do not control the privacy practices of third-party websites that we do not operate. We encourage you to review their privacy policies and terms before providing personal information.

A link to a third-party website does not necessarily mean that WHM Academy endorses that website's privacy practices.

# 20. Social Media and Embedded Content

If our website includes social media links, embedded videos, external forms, or other third-party content, the relevant provider may receive technical information about your visit or collect information when you interact with that content.

The information collected depends on the provider, the integration, and your privacy settings.

Where applicable law requires consent before certain third-party content or tracking technologies are activated, we will use an appropriate consent mechanism.

We encourage you to review the privacy settings and policies of the relevant third-party services.

# 21. Automated Decision-Making and Profiling

WHM Academy may use basic automation to manage subscriptions, organize contacts by the resource requested, send relevant emails, and administer waitlists.

For example, a person who requests the *Built to Exit* checklist may be categorized as a Medtech Innovators contact for the purpose of delivering relevant follow-up communications.

These administrative activities are intended to support the requested service and communication preferences.

We will not use personal information to make decisions producing legal or similarly significant effects about you through solely automated processing unless the activity is permitted by applicable law and any required safeguards are provided.

If our practices change materially, we will update this policy and provide additional disclosures where required.

# 22. Marketing Preferences and Audience Segmentation

To keep communications relevant, WHM Academy may organize contacts according to the resource requested, product purchased, waitlist joined, or communication preferences expressed.

We use these distinctions to administer the relevant service and, where permitted, send communications relevant to that interest.

We do not intend for audience segmentation alone to determine eligibility for essential services or to produce legal or similarly significant effects.

You can manage promotional communication preferences through the available unsubscribe or contact mechanisms.

# 23. Do Not Track and Global Privacy Signals

Some browsers provide privacy signals or settings intended to communicate a user's preference regarding online tracking.

The legal effect and technical operation of these signals vary by jurisdiction and service.

Where applicable law requires us to recognize a particular signal, including a valid opt-out preference signal, we will process it as required.

We do not promise that every browser setting or signal will be recognized by every third-party service integrated with our website.

# 24. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our website, products, data practices, service providers, legal obligations, or operational requirements.

When we make changes, we will update the “Last Updated” date at the top of this page.

Where applicable law requires notice of a material change or renewed consent, we will provide the necessary notice or obtain consent.

We encourage you to review this page periodically to stay informed about how we handle personal information.

# 25. Contact Us

If you have questions about this Privacy Policy, our data practices, or your privacy rights, contact us:

WHM Academy

Legal Business Name: Walnut Hill Medical, LLC

Website: walnuthillmedical.com

Email: [email protected]

Mailing Address: 8350 N. Central Expy., , Suite 1900, PMB #3349 • Dallas, Texas • 75206

Please use the subject line “Privacy Inquiry” or “Privacy Rights Request” so that we can direct your message appropriately.

We will review and respond to legitimate inquiries in accordance with applicable law.

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**End of Privacy Policy**