APALYRX LLC

1. Identity and Licensure

1.1 Legal Identity. ApalyRx LLC is a limited liability company organized under the laws of the State of Texas, operating as a wholly owned subsidiary of Apaly Health Inc., a Delaware corporation. ApalyRx LLC's principal office is located at 802 E. Whiting, Tampa, Florida 33602.

1.2 Texas Class G Pharmacy License. ApalyRx LLC holds a Texas Class G pharmacy license, which authorizes a centralized prescription processing pharmacy to perform the processing and transfer functions described in this document. A Class G pharmacy is a non-dispensing pharmacy. It may process and transfer prescriptions but may not dispense prescription drug products directly to patients.

1.3 National Provider Identifier. ApalyRx LLC's National Provider Identifier (NPI) is 1912873969. This NPI is used in connection with prescription routing, NCPDP transactions, and other administrative functions performed by ApalyRx LLC under the ApalyRx program.

1.4 Multi-State Operations. ApalyRx LLC performs centralized prescription processing functions for prescriptions originating in multiple states. ApalyRx LLC's authority to perform these functions in each state is based on its Texas Class G license and applicable multi-state pharmacy practice laws. ApalyRx LLC does not perform any function that requires a dispensing pharmacy license in any state. All dispensing is performed by Dispensing Pharmacies that hold the required state licenses for dispensing in the applicable state.

1.5 Regulatory Oversight. ApalyRx LLC is regulated by the Texas State Board of Pharmacy. ApalyRx LLC operates in compliance with applicable Texas pharmacy laws and regulations, applicable federal pharmacy laws and regulations including the Drug Supply Chain Security Act, and applicable multi-state pharmacy practice requirements governing centralized prescription processing.

2. Scope of Pharmacy Services

2.1 Authorized Functions. As a Texas Class G centralized prescription processing pharmacy, ApalyRx LLC is authorized to perform the following functions in connection with your prescription:

• Receiving prescriptions transmitted electronically from your prescribing provider via NCPDP SCRIPT or other standard electronic prescription transmission formats
• Verifying the completeness and format of received electronic prescription data
• Performing eligibility verification and benefit configuration checks on behalf of your employer health plan
• Identifying the applicable program channel and designated Dispensing Pharmacy for your prescription based on your health plan's benefit configuration
• Generating and transmitting required transaction data, including Drug Supply Chain Security Act (DSCSA) transaction information, in connection with prescription transfer
• Transferring your prescription electronically to the designated Dispensing Pharmacy for fulfillment
• Receiving and transmitting prescription status information between the Dispensing Pharmacy and the ApalyRx platform
• Performing administrative recordkeeping associated with prescription routing transactions

2.2 Functions Not Performed by ApalyRx LLC. ApalyRx LLC does not and is not authorized to perform any of the following functions:

• Dispensing prescription drug products directly to patients
• Storing, handling, picking, packing, labeling, or shipping prescription drug products
• Taking title to or custody of prescription drug products at any point in the supply chain
• Performing pharmacist verification, drug utilization review, or any other clinical pharmacy function
• Making clinical judgments regarding your prescription, medication, or treatment
• Adjudicating insurance claims or making benefit coverage determinations
• Processing prescriptions for Controlled Substances (Schedules II through V)
• Performing any function that requires a dispensing pharmacy license under applicable state law

3. How ApalyRx LLC Processes Your Prescription

3.1 Receipt of Electronic Prescription. When your prescribing provider transmits a prescription for a covered medication electronically, the prescription is received by ApalyRx LLC via NCPDP SCRIPT or another standard electronic prescription transmission format. ApalyRx LLC does not accept paper prescriptions or prescriptions transmitted by fax in connection with the ApalyRx program.

3.2 Data Verification. Upon receipt of an electronic prescription, ApalyRx LLC verifies the completeness and format of the prescription data. ApalyRx LLC does not perform clinical verification of the prescription. Clinical verification is performed solely by the Dispensing Pharmacy.

3.3 Eligibility and Benefit Check. ApalyRx LLC performs an eligibility and benefit configuration check to confirm that you are an eligible member of a participating employer health plan and to identify the applicable program channel and Dispensing Pharmacy for your prescription. This check is an administrative function performed on behalf of your employer health plan and does not constitute a coverage or medical necessity determination.

3.4 Program Channel Routing. Based on your health plan's benefit configuration and the applicable program channel for your prescription, ApalyRx LLC identifies the designated Dispensing Pharmacy for fulfillment. Your health plan's benefit configuration determines which program channel and Dispensing Pharmacy applies to each covered medication. ApalyRx LLC implements your health plan's routing instructions and does not independently determine routing outcomes.

3.5 Member Notification. Before transferring your prescription to the Dispensing Pharmacy, ApalyRx LLC or Apaly Health will notify you via SMS of your pharmacy options, applicable cost share amount, and other relevant program information. You will have an opportunity to confirm or decline the transaction.

3.6 Prescription Transfer. Upon your confirmation, ApalyRx LLC transfers your prescription electronically to the designated Dispensing Pharmacy. The transfer includes the prescription data and any other information required by the Dispensing Pharmacy to fulfill your prescription in compliance with applicable law. The Dispensing Pharmacy assumes responsibility for your prescription upon receipt of the transfer.

3.7 DSCSA Transaction Data. In connection with prescription transfers under the ApalyRx program, ApalyRx LLC generates and transmits Drug Supply Chain Security Act (DSCSA) transaction information as required by applicable law and program operations. The specific DSCSA functions performed by ApalyRx LLC are described in Section 5 of this document.

3.8 Recordkeeping. ApalyRx LLC maintains administrative records of prescription routing transactions consistent with applicable law and the requirements of the Texas State Board of Pharmacy. These records are available to boards of pharmacy and other regulatory authorities upon request within required timeframes.

4. Custody Without Title Model

4.1 No Title Transfer at ApalyRx LLC. ApalyRx LLC does not purchase, take title to, or take custody of prescription drug products under the ApalyRx program. Prescription drug products remain the property of the applicable Program Supplier until title transfers to the Dispensing Pharmacy at the time of dispense to you. ApalyRx LLC operates as a prescription processing and routing intermediary only, without any proprietary interest in the physical drug products at any point in the supply chain.

4.2 Significance of Custody Without Title. The custody-without-title model is fundamental to the legal and regulatory structure of the ApalyRx program. By not taking title to or custody of prescription drug products, ApalyRx LLC maintains its status as a centralized prescription processing pharmacy rather than a distributor or wholesale distributor under applicable state and federal law. This structure allows Program Suppliers to retain a commercial relationship with the patient through the point of dispense, providing pricing transparency and enabling the manufacturer-to-patient commercial relationship that makes the ApalyRx program possible.

4.3 Title Transfer at Dispense. Title to prescription drug products transfers from the applicable Program Supplier to the designated Dispensing Pharmacy at the time of dispense to you. The Dispensing Pharmacy is the pharmacy of record and takes title to and responsibility for the drug product upon dispensing. This title transfer structure is consistent with applicable state pharmacy laws and federal drug distribution regulations.

4.4 No Warehouse or Storage Function. ApalyRx LLC does not warehouse, store, or hold prescription drug products at any location. ApalyRx LLC does not operate a pharmacy that maintains physical drug inventory. All physical handling of prescription drug products, including storage, packaging, and shipment, is performed by the Dispensing Pharmacy or by third-party logistics providers acting under the authority of the Program Supplier or Dispensing Pharmacy.

5. Drug Supply Chain Security Act Compliance

5.1 DSCSA Overview. The Drug Supply Chain Security Act (DSCSA), codified at 21 U.S.C. Section 360eee et seq., requires that each change of ownership of a prescription drug product in the pharmaceutical supply chain be accompanied by transaction information, transaction history, and a transaction statement (collectively, Transaction Information). The DSCSA is designed to build an electronic, interoperable system to identify and trace certain prescription drugs as they are distributed throughout the United States.

5.2 ApalyRx LLC's DSCSA Function. ApalyRx LLC performs a specialized DSCSA compliance function within the ApalyRx program. Because ApalyRx LLC does not take title to prescription drug products, standard DSCSA change-of-ownership triggers do not apply to ApalyRx LLC's prescription processing activities. However, ApalyRx LLC generates and transmits Transaction Information associated with each prescription transfer in connection with program operations to support the Dispensing Pharmacy's DSCSA compliance obligations at the point of dispense.

5.3 Serialized Prescription Allocation. In connection with the ApalyRx program, prescription drug products covered by the program are associated with serialized National Drug Code (NDC) identifiers that are maintained in a virtual pre-allocation system. When your prescription is transferred by ApalyRx LLC to the Dispensing Pharmacy, the relevant serialized unit information is allocated and locked to your prescription transaction. This allocation occurs without a change of ownership of the physical product.

5.4 Automatic Transaction Information Generation. ApalyRx LLC automatically generates Transaction Information associated with each prescription transfer at the time the prescription is released for fulfillment. This automated generation of Transaction Information supports the Dispensing Pharmacy's ability to receive and verify the product at the point of dispense without requiring manual documentation of the routing transaction.

5.5 Dispensing Pharmacy DSCSA Obligations. The Dispensing Pharmacy is responsible for all DSCSA obligations applicable to dispensing pharmacies, including receiving and verifying Transaction Information, maintaining transaction records, and complying with any applicable DSCSA product tracing requirements. ApalyRx LLC supports the Dispensing Pharmacy's compliance by providing accurate and complete Transaction Information at the time of prescription transfer.

5.6 Regulatory Recordkeeping. ApalyRx LLC maintains records of prescription routing transactions, Transaction Information generated, and related administrative data consistent with applicable DSCSA requirements and Texas State Board of Pharmacy regulations. These records are available to the Food and Drug Administration, state boards of pharmacy, and other regulatory authorities upon request consistent with applicable law.

6. Controlled Substances

6.1 Controlled Substances Are Outside Scope. ApalyRx LLC does not process prescriptions for Controlled Substances as defined under the federal Controlled Substances Act (21 U.S.C. Section 802) and applicable state law, including Schedules II through V. Controlled substance prescriptions are expressly outside the scope of ApalyRx LLC's Class G pharmacy license and the ApalyRx program.

6.2 Handling of Inadvertently Received Controlled Substance Prescriptions. If a prescription for a Controlled Substance is inadvertently received by ApalyRx LLC through the ApalyRx platform, ApalyRx LLC will reject the transaction from program workflows and will not route or transfer the prescription through the ApalyRx program. You will be notified via SMS or through your account and the prescription will be available for transfer to a pharmacy of your choice.

6.3 DEA and PDMP Obligations. ApalyRx LLC does not hold a Drug Enforcement Administration (DEA) registration for dispensing Controlled Substances and has no obligations under the Controlled Substances Act for dispensing. All DEA registration, PDMP reporting, and controlled substance dispensing obligations rest solely with the licensed Dispensing Pharmacies that dispense controlled substances outside the ApalyRx program.

7. Privacy and Data Handling

7.1 ApalyRx LLC as Subcontractor Business Associate. ApalyRx LLC operates as a subcontractor Business Associate of Apaly Health Inc. under a Business Associate Agreement consistent with HIPAA and its implementing regulations. In this capacity, ApalyRx LLC handles your Protected Health Information only as necessary to perform the prescription processing and routing functions described in this document, and only in accordance with Apaly Health's obligations as a Business Associate of your employer health plan.

7.2 Minimum Necessary Standard. ApalyRx LLC accesses and uses your Protected Health Information only to the minimum extent necessary to perform its authorized prescription processing and routing functions. ApalyRx LLC does not use your Protected Health Information for any purpose beyond those authorized by your HIPAA Authorization at apalyrx.com/legal and applicable law.

7.3 Data Security. ApalyRx LLC maintains reasonable and appropriate administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of your Protected Health Information consistent with HIPAA Security Rule requirements.

7.4 No Independent Data Use. ApalyRx LLC does not independently use, sell, or disclose your health information for any purpose other than performing its authorized pharmacy processing and routing functions on behalf of Apaly Health Inc. and your employer health plan.

8. Relationship to Apaly Health Inc.

8.1 Wholly Owned Subsidiary. ApalyRx LLC is a wholly owned subsidiary of Apaly Health Inc. ApalyRx LLC operates as a licensed pharmacy entity within the ApalyRx prescription benefit platform operated by Apaly Health Inc. The prescription processing and routing functions performed by ApalyRx LLC are performed as part of the ApalyRx program administered by Apaly Health Inc. on behalf of your employer health plan.

8.2 Technology Platform Relationship. ApalyRx LLC uses the technology platform operated by Apaly Health Inc. to perform its prescription processing and routing functions. Apaly Health Inc. provides the technology infrastructure, member interface, eligibility connectivity, and program administration services that support ApalyRx LLC's pharmacy operations. ApalyRx LLC provides the licensed pharmacy entity through which prescription routing and DSCSA functions are performed.

8.3 Coordinated Compliance. Apaly Health Inc. and ApalyRx LLC coordinate their compliance obligations to ensure that the ApalyRx program operates in accordance with applicable federal and state pharmacy laws, HIPAA, DSCSA, and other applicable regulations.

9. Regulatory Contacts and Complaints

9.1 Texas State Board of Pharmacy. ApalyRx LLC is regulated by the Texas State Board of Pharmacy. Questions or complaints regarding ApalyRx LLC's pharmacy operations may be directed to the Texas State Board of Pharmacy at 333 Guadalupe Street, Tower 3, Suite 600, Austin, Texas 78701, telephone (512) 305-8000, or at www.pharmacy.texas.gov.

9.2 Contact ApalyRx LLC. For questions about ApalyRx LLC's pharmacy services or your prescription routing transaction, contact Apaly Health at:

• Email: privacy@apalyrx.com
• Mail: ApalyRx LLC, c/o Apaly Health Inc., 802 E. Whiting, Tampa, Florida 33602
• Account: apalyrx.net

9.3 FDA and DSCSA Complaints. Questions or complaints regarding DSCSA compliance or drug supply chain integrity may be directed to the U.S. Food and Drug Administration at www.fda.gov or by calling 1-888-INFO-FDA (1-888-463-6332).

10. Changes and Updates

10.1 Changes to These Terms. ApalyRx LLC or Apaly Health may update these Pharmacy Services Terms from time to time by updating the document at apalyrx.com/legal. Your continued use of the ApalyRx program following any update constitutes your acceptance of the updated terms.

10.2 Regulatory Changes. Changes in applicable pharmacy laws, DSCSA requirements, or other regulations may require changes to the scope or manner of ApalyRx LLC's operations. ApalyRx LLC will update these terms to reflect any material changes to its authorized scope of activities resulting from regulatory changes.

11. Member Acknowledgments

By accepting the Apaly Health Inc. Terms of Use and these ApalyRx LLC Pharmacy Services Terms, you confirm the following:

• You understand that ApalyRx LLC is a Texas Class G centralized prescription processing pharmacy that routes and transfers prescriptions and does not dispense medications directly to patients
• You understand that ApalyRx LLC does not take title to or custody of prescription drug products at any point
• You understand that all dispensing is performed solely by the designated Dispensing Pharmacy
• You understand that ApalyRx LLC does not perform clinical pharmacy functions, does not adjudicate benefits, and does not make coverage or medical necessity determinations
• You understand that ApalyRx LLC performs DSCSA transaction information functions in connection with prescription transfers under the ApalyRx program
• You understand that controlled substances are outside the scope of ApalyRx LLC's license and the ApalyRx program
• You understand that ApalyRx LLC handles your Protected Health Information only as necessary to perform its authorized prescription processing functions, as a subcontractor Business Associate of Apaly Health Inc.
• You understand that ApalyRx LLC is regulated by the Texas State Board of Pharmacy