Effective Date: July 30, 2023

Last Updated: April 19, 2026

In strict adherence to Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and the directives of the National Privacy Commission (NPC) of the Philippines, StrataMedica (the “Company,” “we,” “us,” or “our”) is committed to protecting the fundamental human right to privacy while ensuring the free flow of information to promote innovation and growth.

1. INTRODUCTION

   This Data Privacy Policy (the “Policy”) outlines our practices regarding the collection, use, storage, and protection of information obtained through our platform. By accessing our services, you acknowledge that you have read, understood, and agreed to the terms of this Policy.

2. PERSONAL INFORMATION CONTROLLER

   StrataMedica serves as the Personal Information Controller (PIC) as defined under the DPA. This means we are responsible for the control and processing of your personal data and determine the specific purposes for which such data is utilized.

3. CATEGORIES OF INFORMATION COLLECTED

   To provide our specialized services effectively, we collect and process the following:

   1. Personal Information: Information that establishes your identity, including but not limited to your full name, primary email address, mobile/telephone number, and permanent or current residential address.
   2. Sensitive Personal Information: Given the nature of our services, we process information concerning an individual's health, including medical history, therapy records, psychological assessments, and other related clinical data.
   3. Technical and Usage Data: Automatically collected data such as Internet Protocol (IP) addresses, browser types, device identifiers, cookies, and telemetry regarding your interaction with our digital interfaces.
4. PURPOSE OF PROCESSING

   The processing of personal data is anchored on the principles of Transparency, Legitimate Purpose, and Proportionality. Data is processed for:

   • Service Facilitation: Managing bookings, appointments, and the delivery of therapeutic services.
   • Administrative Operations: Identity verification, secure payment processing, and customer support.
   • Service Optimization: Internal analytics to improve system functionality and user experience.
   • Legal Compliance: Adhering to statutory requirements, tax obligations, and lawful orders from government agencies.
5. LEGAL BASIS FOR PROCESSING

   We process your data based on the following legal frameworks:

   • Consent: Explicit permission granted by you for specific processing activities.
   • Contractual Necessity: Processing required to fulfill our obligations under the Service Agreement.
   • Legal Obligation: Processing mandated by Philippine law or regulatory bodies.
6. DATA SHARING AND DISCLOSURE

   We do not sell, rent, or lease your personal data to third parties. Disclosure is limited to:

   • Authorized Personnel: Licensed Therapists and clinical staff directly involved in your care.
   • Service Providers: Third-party partners (e.g., payment gateways, cloud hosting) bound by strict Data Sharing Agreements (DSA).
   • Law Enforcement: When such disclosure is necessary to comply with a judicial proceeding or legal process.
7. DATA SECURITY MEASURES

   The Company employs a "Defense-in-Depth" strategy to protect your information, utilizing:

   • Technical Safeguards: Advanced encryption protocols (AES-256) for data at rest and in transit.
   • Physical Safeguards: Secure data centers and restricted access to physical files.
   • Organizational Safeguards: Regular staff training, non-disclosure agreements (NDAs), and periodic privacy impact assessments.
8. RETENTION AND DISPOSAL

   Personal data shall be retained only for as long as necessary to fulfill the purposes outlined in this Policy or as required by clinical record-keeping regulations. Upon the expiration of the retention period, data shall be disposed of through secure de-identification or physical destruction to prevent further processing.

9. RIGHTS OF THE DATA SUBJECT

   As a data subject under the DPA, you are entitled to:

   • Right to be Informed: To know whether your data is being processed.
   • Right to Access: To demand reasonable access to your personal information.
   • Right to Rectification: To dispute and correct inaccuracies in your records.
   • Right to Erasure/Blocking: To request the removal of your data from our systems.
   • Right to Damages: To be indemnified for any damages sustained due to inaccurate, incomplete, or unauthorized use of personal data.
10. DATA BREACH NOTIFICATION

    In compliance with NPC Circular No. 16-03, StrataMedica maintains a Data Breach Response Team. In the event of a confirmed personal data breach, we will notify the affected users and the National Privacy Commission within seventy-two (72) hours of knowledge of the breach.

11. AMENDMENTS

    The Company reserves the right to modify this Policy at any time. Changes will be effective immediately upon posting the revised version on our platform. Your continued use of our services constitutes an acceptance of the updated Policy.

12. CONTACT INFORMATION

    For inquiries, requests for access, or concerns regarding your privacy rights, please contact our Data Protection Officer (DPO):.

    Attention: Data Protection Officer

    Address: Naga City, Philippines

    Email: admin@stratamedica.com

By registering for an account and using our services, you acknowledge that you have read, understood, and agree to the terms of this Data Privacy Policy.

Last Updated: April 19, 2026

Platform Name: StrataMedica

Company: StrataMedica

These Terms and Conditions ("Agreement") constitute a legally binding agreement between StrataMedica ("Company," "we," "us," or "our") and the users ("User," "you," or "your") of the StrataMedica digital marketplace (the "Platform"). By accessing or using the Platform, you agree to be bound by these terms.

1. PLATFORM OVERVIEW & SCOPE OF SERVICES

   StrataMedica serves exclusively as a digital intermediary marketplace designed to facilitate connections between Patients seeking rehabilitative care and Licensed Physical Therapists ("Therapists") providing home-based or clinic-based services within the Philippines.

   1. Legal Disclaimer on Services: The Company is not a medical provider, clinic, or healthcare facility. We do not provide physical therapy, medical advice, or clinical services. All professional services are rendered by independent third-party Therapists who are not employees, agents, or representatives of the Company.
2. CLASSIFICATION OF USERS

   • Patient / Client: Any individual or legal guardian registering to browse, request, or book rehabilitative services.
   • Therapist / Partner: An independent, PRC-licensed Physical Therapist offering professional services via the Platform.
   • Administrator: Personnel authorized by the Company to manage Platform operations and oversight.
3. ACCOUNT REGISTRATION & SECURITY

   To access certain features, you must create a secure account. By registering, you warrant and agree to:

   • Provide accurate, current, and complete personal and medical history information.
   • Maintain the confidentiality of your account credentials.
   • Accept full legal responsibility for all activities, bookings, and communications conducted through your account.
4. BOOKING MECHANISM & CONTRACTUAL RELATIONSHIP

   The Platform facilitates the scheduling of appointments through a request-and-acceptance model.

   1. Formation of Contract: A legally binding service contract is formed directly between the Patient and the Therapist once a booking is confirmed. The Company is not a party to this bilateral service agreement.
   2. Right of Refusal: Therapists reserve the right to accept or decline any booking request based on their professional judgment, availability, or location.
5. FINANCIAL TERMS & CANCELLATION POLICY

   All financial transactions are processed through authorized third-party gateways (e.g., [GCash / PayMongo / Stripe]).

   1. Fee Structure: The Company may collect a Service Fee from the Patient and/or a Commission Fee from the Therapist for the use of the Platform’s infrastructure.
   2. Cancellation & Refunds:
      1. ≥ 24 Hours Notice: Eligible for a full refund of the booking fee (subject to processing fees).
      2. < 24 Hours Notice: Subject to a partial refund or total forfeiture of the booking fee to compensate the Therapist for lost time.
6. MEDICAL DISCLAIMER & INDEPENDENT JUDGMENT

   The Platform does not guarantee specific health outcomes or medical improvements.

   1. Physician Consultation: Patients are strongly advised to seek a physician’s clearance before commencing physical therapy.
   2. Clinical Autonomy: Therapists exercise sole professional discretion regarding treatment plans, modalities, and assessments. The Company does not interfere with clinical decision-making.
7. THERAPIST VERIFICATION (CREDENTIALING)

   While the Company performs reasonable due diligence—including the verification of Professional Regulation Commission (PRC) licenses and certifications—we do not warrant the continuous validity of a Therapist's credentials. Users are encouraged to exercise independent caution.

8. PROHIBITED CONDUCT & ANTI-CIRCUMVENTION

   Users strictly agree to refrain from:

   1. Misrepresentation: Falsifying identity, PRC license status, or medical necessity.
   2. Harassment: Any form of verbal, physical, or digital abuse toward other Users.
   3. Anti-Circumvention: Attempting to bypass the Platform’s payment system to avoid service fees. Engaging in "off-platform" transactions for connections initiated via StrataMedica is a material breach of this Agreement.
9. LIMITATION OF LIABILITY

   To the maximum extent permitted by Philippine law, StrataMedica shall not be liable for:

   1. Any physical injury, medical complications, or professional malpractice arising from Therapist services.
   2. Direct or indirect disputes between Patients and Therapists.
   3. Technical interruptions, missed appointments, or loss of data.
10. TERMINATION OF ACCESS

    The Company reserves the right, at its sole discretion, to suspend or terminate any account without prior notice for:

    1. Suspected fraudulent or illegal activity.
    2. Violation of the Anti-Circumvention clause.
    3. Failure to adhere to the professional standards of the Platform.
11. GOVERNING LAW & JURISDICTION

    This Agreement shall be governed by and construed in accordance with the laws of the Republic of the Philippines. Any legal action arising from these terms shall be filed exclusively in the competent courts of Naga City, Philippines.

12. CONTACT INFORMATION

    For inquiries regarding these Terms, please contact our legal compliance team at:

    • Email: admin@stratamedical.com
    • Office Address: Naga City, Philippines

By participating as a partner therapist in our platform, you acknowledge that you have read, understood, and agree to our Terms & Conditions.