This notice is intended to supplement the Eden Health (“Eden”) Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (“MHMD”).

‍

Consumer Health Data We Collect

The data we collect depends on the context of your interactions with Eden and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data. As described in “Information We Collect” section of our Privacy Policy, the data we collect depends on the context of your interactions, but primarily comes from information you choose to submit to Eden information based on your privacy settings, and your location. Because consumer health data is defined very broadly, certain of the categories of data we collect could also be considered consumer health data.

Examples of consumer health data may include:

• Information about your health-related conditions, injuries, symptoms, status, diagnoses, testing, medications, allergies, or treatments (including surgeries, procedures, medications, blood test results, or other interventions). For example, if you are looking to connect with a physician who is licensed in your state to provide you with a metabolic health assessment and prescribe medications, we may collect some or all of this information to provide the services.
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, if you allow Google Analytics in your cookie permissions, we may collect location data that could reveal your location and your interest in receiving health care services to connect you to a physician who is licensed in your state.
• 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, we may collect information about information you viewed, which may indicate your attempt to learn more about certain conditions that you or another person may have, or based on products descriptions you clicked on to explore whether certain prescription medications may be right for you.
• Other information that may be used to infer or derive data related to the above or other health information.

‍

Sources of Consumer Health Data

As described further in the Privacy Policy, we collect personal data (which may include consumer health data) directly from you and from your interactions with our Services. We may use cookies to collect certain information that you agree to in our Cookie Consent. We will not collect any information via cookies without your consent.

‍

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 Policy. We collect personal data (which may include consumer health data) directly from you, from your interactions with our Services.

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law –for example, to respond to an inquiry through our Contact Us form. See the “Your Choices”  and “Your Rights”  sections of the Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

‍

How we share consumer health data

We may share each of the categories of consumer health data described above for the purposes described in the How We Share and Disclose Your Information  section of the Privacy Policy. In particular, we may share personal data, including consumer health data, with your consent, when you tell us to do so, or as reasonably necessary to deliver the Services or respond to an inquiry, including sharing with physicians and pharmacies who are licensed in your area who want to provide you with products or services at your request. We may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

‍

With whom we share consumer health data

We provide certain health care providers and business partners with your consumer health data so that we can provide you with the services you requested. For example, if you are connected to a physician who is licensed in your state to provide you with products or services, we need to provide your consumer health data to that physician so they can perform a health assessment and, if applicable, prescribe certain medications. We may also share your consumer health data with pharmacy partners so they can fill your prescription. When you create an account with Eden, you authorize us to collect and provide this information to these partners. As necessary for the purposes described above and to provide you with the Service, 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 protect and secure data, or provide products or services you are interested in, may need access to data to provide those functions.
• 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.
• Government agencies. As described in our Privacy Policy we may be required to disclose 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.
• Affiliates. We enable access to data across 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.

‍

How to exercise your rights

Eden requires you to provide affirmative consent to (i) collection and (ii) sharing and (iii) sale of your consumer health data as described in this Policy and the Privacy Policy when you first access the services.

MHMD provides consumers with certain rights regarding their 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 emailing [email protected] to request access, correction, or deletion of consumer health information, or to withdraw consent from future collection or sharing of consumer health data. You may also opt out of Google Analytics services using the Opt-Out feature provided by Google or by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout.

If you submit a rights request to [email protected], we will respond to that request within the period of time required under MHMD.

If your request to exercise a right under the MHMD is denied, you may appeal that decision by emailing [email protected]. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.