Effective:  May 17, 2024

This Consumer Health Data Privacy Policy (this “Policy”) supplements MindGlow Health’s Privacy Policy and applies to the collection of “consumer health data” subject to the Washington My Health My Data Act (“MHMDA”) collected through our website and mobile application. This Policy does not apply to information or practices that are not subject to the MHMDA, such as publicly available information, personal health information governed by the Health Insurance Portability and Accountability Act of 1996 and related regulations (“HIPAA”), which is governed by our HIPAA Notice of Privacy Practices, personal information governed by the Fair Credit Reporting Act, or job applicant and employee information.  

This Policy does not apply to provision of mental health and substance abuse services that we directly provide, as the personal information we collect in that context is subject to HIPAA and exempt from the MHMDA. This Policy applies to general website visitors and those who engage with MindGlow Health outside of receiving direct telehealth services from MindGlow Health professionals.

1. The Categories of Consumer Health Data We Collect

The data we collect depends on the context of your interactions with MindGlow Health. Due to the broad definition of “consumer health data” under MHMDA, many of the categories of data we collect could also be considered consumer health data. We may collect the following categories of “consumer health data”: 

• Individual health conditions, treatment, diseases, or diagnosis;
• Health-related surgeries or procedures;
• Use or purchase of prescribed medication;
• Social, psychological behavioral, and medical interventions; 
• Bodily functions, vital signs, symptoms, or measurements of the information described in this Section 1;
• Data that identifies a consumer seeking healthcare services, such as internet, network, or other electronic activity relating to your interaction with our websites or advertisements;
• Information processed to associate or identify a consumer with the data described above that is derived or extrapolated from non-health information. 

2. Purposes of Collection and How MindGlow Health Uses Consumer Health Data

Generally, we may collect and use the consumer health data that we collect for the purposes set forth below:

• As reasonably necessary to provide you with the products or services you have requested;
• To provide support in connection with the use of our products and services;
• To enroll you in our membership plans and/or subscriptions;
• To communicate with you;
• To establish and manage your account;
• To administer the services and our relationship with you;
• To send you updates about MindGlow Health and the products and services we offer;
• To detect security incidents;
• To protect against malicious or illegal activity;
• To ensure the appropriate use of our products and services;
• To improve our products and services and to develop new products and services;
• For short-term transient use of online identifiers;
• For quality and safety assurance;
• For internal research and development to evaluate the effectiveness of our products and services;
• For purposes of marketing, advertising, and product promotion, including to contact you regarding our programs, products, and services, surveys, and topics that be of interest or useful to you; and
• To comply with our legal and regulatory obligations. 

3. The Categories of Sources From Which We Collect Consumer Health Data

In general, we may collect consumer health data from the following categories of sources:

• Directly from you;
• Those authorized to provide personal information on your behalf, such as your guardian, caregiver, or authorized representative;
• Your devices;
• Wholly owned lead websites and resources;
• Data analytics partners; and
• Advertising networks. 

4. The Categories of Consumer Health Data That We Share

We may share the following categories of consumer health data with third parties and affiliates:

• Individual health conditions, treatment, diseases, or diagnosis;
• Health-related surgeries or procedures;
• Use or purchase of prescribed medication;
• Social, psychological behavioral, and medical interventions; 
• Bodily functions, vital signs, symptoms, or measurements of the information described in Section 1;
• Data that identifies a consumer seeking healthcare services, such as internet, network, or other electronic activity relating to your interaction with our websites or advertisements;
• Information processed to associate or identify a consumer with the data described above that is derived or extrapolated from non-health information.

5. The Categories of Third Parties and Specific Affiliates with Whom We Share Consumer Health Data

MindGlow Health may share the categories of consumer health data included in Section 4 with the following categories of third parties and specific affiliates:

• Affiliates including FHE Health;
• Government entities;
• Regulators;
• Operating systems and platforms;
• Those authorized to act on your behalf, such as your guardian, caregiver, or authorized representative;
• Third parties we, our affiliates, or subsidiaries are or may be acquired by, merged with, financed by, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and other advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction; and
• Advisors and agents.

Your Privacy Rights

MHMDA provides consumers with the following rights:

• Know/Access: The right to confirm whether MindGlow Health collects, shares, or sells your consumer health data and the right to access such consumer health data;
• Withdraw consent: The right to withdraw consent from MindGlow Health’s collection and sharing of your consumer health data; and 
• Deletion: The right to have your consumer health data deleted.

Exercising Your Privacy Rights

Requests to Know/Access and Delete

To make a request to know/access or delete your consumer health data, please email us at support@MindGlowHealth.com. Before completing your request, we may need to verify your identity or your authority to make a request on behalf of another person. We may send you a link to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity, depending on the type of your request. 

Requests to Withdraw Consent

• Collection: To opt out of MindGlow Health’s collection of your consumer health data, please email us at support@MindGlowHealth.com. Please note that if you withdraw your consent to MindGlow Health’s collection of your consumer health data, we may be limited in the manner in which we can provide our services to you. 

• Sharing: To opt out of MindGlow Health’s sharing of your consumer health data with third parties and affiliates, please email us at support@MindGlowHealth.com.

If your request to exercise a right under the MHMDA is denied, we will provide instructions for how you can appeal our decision. If your appeal is unsuccessful, you can file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.