Consumer Health Data Privacy Notice
Last updated March 19, 2025
This Consumer Health Data Privacy Notice (“Health Data Notice”) supplements our General Privacy Notice (“Privacy Notice”) and applies to personal data defined as “consumer health data” subject to the Washington My Health My Data Act (MHMDA), the Nevada Health Data Privacy Act (NHDPA), or other applicable state consumer health privacy law (together, the “Consumer Health Data” laws).
I. Consumer Health Data We Collect
As described in the Information We Collect section of the Privacy Notice, the data We collect depends on how you interact with us, the services you use, and the choices you make. Because consumer health data is defined very broadly, some of the categories of data We collect could be considered consumer health data.
Such data may be categorized as follows:
- Measurements of bodily functions, vital signs, or characteristics, such as blood alcohol levels and photos (which may include face imagery and therefore be considered biometric information under the MHMDA).
- Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, we may collect GPS location data that could reveal your location being adjacent to or at a health care facility.
- Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, if you request to share information with a health care provider, that could reveal the types of health or wellness care or services you are seeking.
- Other information that may be used to infer or derive data related to the above or other health information.
II. Sources of Consumer Health Data
As described further in the Information We Collect section of the Privacy Notice, We collect personal data (which may include consumer health data) directly from you, from your interactions with our products and services, from third parties, and from publicly available sources.
III. Why We Collect and Use Consumer Health Data
We collect and use consumer health data for the purposes described in the How We Use Your Information section of the Privacy Notice. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the Services you have requested or authorized. For example, we may collect information about your blood alcohol level in connection with your use of the Services. We use this information in connection with delivering and operating the Services and their features, personalization of certain features, enabling you to disclose your information to third parties that you authorize, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the Services, and other essential business operations that support the provision of the products (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).
See the Your Choices Regarding Your Information section of the Privacy Notice and the How to Exercise Your Rights section below for more details on the controls and choices you may have.
IV. Our Sharing of Consumer Health Data
We may share each of the categories of consumer health data described above for the purposes described in the How Your Information Is Disclosed section of the Privacy Notice. In particular, We may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any Services you have requested or authorized, as described in the previous section above.
For example, We share your information with third parties when you tell us to do so, such as when you direct us to provide reports to third parties or when you would like to provide those reports yourself. If you make a purchase, We will share information about the transaction as necessary to process the payment, including protection against fraud. We may disclose data when We believe that doing so is necessary to comply with applicable law or respond to valid legal process.
V. Third Parties with Which We Share Consumer Health Data
As necessary for the purposes described above, We share consumer health data with the following categories of third parties:
- Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to data to provide those functions. When you make a purchase or enter into a financial transaction, We will also disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
- Business partners. We may share consumer health data with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use the Services to interact with another company.
- Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
- Affiliates/Mindr Brands. Unless restricted by law, we enable access to data across Mindr’s family of brands, which includes our subsidiaries, affiliates, and related companies. For example, where We share common data systems or where access helps us to provide our services and operate our business.
- Government agencies. We will disclose consumer health data to law enforcement or other government agencies when We believe doing so is necessary to comply with applicable law or respond to valid legal process.
- Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
- Other users and individuals. If you use our services to interact with other users of the service or other recipients of communications, We will share data, including consumer health data, as directed by you and your interactions.
VI. How to Exercise Your Rights
Residents of states with Consumer Health Data laws are entitled to certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in the Your Choices Regarding Your Information section of the Privacy Notice or by using our web form.
If your request to exercise a right is denied, you may appeal that decision by contacting our privacy support team via our web form.
VII. Material changes to this Privacy Notice
We’ll notify you before we make material changes to this Health Data Notice. If you do not agree with the changes to how your personal information will be used, please do not continue to use this website. Your continued use of the website or Services after you have been notified of changes to the Health Data Notice will mean that you accept and agree to the changes to this Health Data Notice. Please review this Health Data Notice periodically, and especially before you provide any information. This Health Data Notice was made effective on the date indicated above.
VIII. Contact Information
If you have questions or comments about this Health Data Notice, our privacy policies, the ways in which We collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under Washington or Nevada law, please contact us at:
Toll-Free Phone: 833-989-1425
Mail: Mindr
Attn: Legal Dept, Privacy
12421 Meredith Drive, Suite 100
Urbandale, IA 50323