This Consumer Health Data Privacy Policy describes Twentyeight Health’s (“Twentyeight Health,” “we,” “us,” or “our”) privacy practices for “consumer health personal data” as defined under applicable U.S. state laws.

Consumer health data is any data that is linked or reasonably linkable to a specific individual and that identifies that individual’s past, present, or future physical or mental health status that Company collects or controls the collection of (“consumer health data”).

This Policy applies to the sites, products, applications, platforms, or other services linking to this Policy. This Policy does not apply to any sites, products, applications, platforms, or other services not directly linking to this Policy.

It is important to note that Twentyeight Health collects and creates Protected Health Information (“PHI”) as part of its services as a Business Associate regulated by the federal Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Any health data we collect which constitutes PHI is exempt from both U.S. state consumer health data privacy laws and the terms of this Consumer Health Data Privacy Policy. Most, if not all, health data we collect constitutes PHI. Other information exempt from U.S. state consumer health data privacy laws and, thus, this Consumer Health Data Privacy Policy, includes information that originates from, and is intermingled to be indistinguishable with, PHI. After a review of our data collection practices, we are of the opinion that we collect little “consumer health data.” However, to the extent applicable, this Consumer Health Data Privacy Policy governs any consumer health data which is not exempt from U.S. state consumer health data privacy laws. To view our privacy policy describing how we treat other personal information, visit https://www.twentyeighthealth.com/privacy. 

Please read this Policy carefully to understand our policies and practices regarding your consumer health data and how we will treat it. If you do not agree with our policies and practices, you should not use the sites, products, applications, platforms, or other services linking to this Policy.

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Consumer Health Data We May Collect About You

We collect and use the following types of consumer health data from and about you:

• Data identifying a consumer seeking health care services. Health care services means any service provided to a person to assess, measure, improve, or learn about a person’s mental or physical health, including but not limited to:
  
  • individual health conditions, status, diseases, or diagnoses;
  • social, psychological, behavioral, and medical interventions;
  • health-related surgeries or procedures;
  • use or purchase of medication;
  • bodily functions, vital signs, symptoms, or measurements;
  • diagnoses or diagnostic testing, treatment, or medication;
  • reproductive health care services; or
  • gender-affirming care services.
• Any inferences of the above categories derived, extrapolated, or inferred from non-health information.

We use these categories of consumer health data for the following purposes:

• Improving our products and services.
• Facilitating services and operations performance, security, and integrity, including:

• undertaking activities to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted consumer health data or that otherwise threaten to compromise the performance, security, or integrity of our business; and
• performance analytics, identity verification and authorization, site and application optimization, and quality control.

• Recordkeeping and auditing.
• Administering customer accounts and preferences.
• Measuring or understanding the effectiveness of non-personalized advertising and delivering non-personalized advertising served as part of your current interaction with you.
• Our internal research and product or service design and development.

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Consumer Health Data Sources

We collect consumer health data from the following sources:

• You, including when you request information about our services and sign up for email lists or programs.
• Your device when you visit or interact with our sites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our sites, applications, or services.
• Our business and marketing partners, who provide us with information about consumers who are viewing our content across other websites or applications, purchasing our products, or interacting with our promotions, benefits, or programs.
• Other third-party sources, such as data brokers who provide us with information about consumers that may be interested in our products or services.

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Consumer Health Data Disclosures

We do not sell your consumer health data.

We may disclose any of the consumer health data categories listed above to processors, service providers, and contractors that help us provide products and services to you. 

We instruct these processors, service providers, and contractors to only use consumer health data as permitted by our contracts with them and consistent with applicable law.

We may also disclose consumer health data as permitted by applicable law, including:

• With your consent.
• To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities.
• To a third party acquiring our assets if we sell our business or otherwise are part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control of our assets or business.
• To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others.
• To protect your or others’ vital interests, including health and safety.

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Your Privacy Rights

You have specific rights with respect to your consumer health data. You have the right to:

• Request confirmation that we collect and/or share your consumer health data.
• Request access to your consumer health data that we have collected or control.
• Withdraw your consent for our collection and sharing of your consumer health data.
• Request that we delete your consumer health data.

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Contact Information

To exercise any of your rights, or to make an inquiry or comment about this Policy or our privacy practices, contact us at contact@twentyeighthealth.com or via our toll-free number: [insert toll-free number].

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