Last Updated: August 19, 2024

This notice supplements our Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA) or Nevada’s Consumer Health Data Privacy Law. Capitalized terms not defined in this Consumer Health Data Privacy Policy are defined in the Privacy Policy.

Please note that data practices concerning Protected Health Information we collect are described in the terms and privacy disclosures specific to those services.

Consumer Health Data We Collect

As described in the Privacy Policy, the data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services and features you use, your location, and applicable law.

Examples of consumer health data we collect include:

• Information about your (i) individual health conditions, treatment, diseases, or diagnosis; (ii) social, psychological, behavioral, and medical interventions; (iii) health-related surgeries or procedures; (iv) use or purchase of prescribed medication; (v) bodily functions, vital signs, symptoms, or measurements of the information described in this Consumer Health Data Privacy Policy; (vi) diagnoses or diagnostic testing, treatment, or medication;(vii) Gender-affirming care information; (viii) reproductive or sexual health information; (ix) genetic data; (x) precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies; (xi) data that identifies you seeking health care services. Any information that we or our processor(s), processes to associate or identify you with the data described in this Consumer Health Data Privacy Policy that is derived or extrapolated from nonhealth information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).

Sources of Consumer Health Data

As described further in our Privacy Policy, we collect personal data (which may include consumer health data) directly from you, from your interactions with our Services, from third parties, and from publicly available sources.

Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in our Privacy Policy. Primarily, we collect and use consumer health data for the following purposes:

• providing you with the Services and information you request;
• enabling users to use our Services and their features;
• administering the Services and your account with us;
• processing and fulfilling your transactions;
• furthering our business purposes, such as quality assessment, data analysis, audits, developing new products and services, enhancing the services, identifying usage trends, and determining the effectiveness of our promotional campaigns;
• responding to your requests, questions, and concerns;
• conducting research surveys and market research;
• developing new features and offerings on the Services;
• facilitating marketing and communications with you, including information about products and services of ours and of others, that we think might interest you;
• protecting our rights and property;
• recovering debt and preventing fraud;
• customizing our Services to your interests and history with us;
• other purposes disclosed when Personal Data is submitted to us;
• for any purposes for which we obtain your consent.

See our Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

As described in our Privacy Policy, we may create aggregate/de-identified data from the information we collect through the Services and our disclosure of such aggregate/de-identified data is at our discretion.

Third Parties with which We Share Consumer Health Data

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

• our consulting physicians, psychologists, and other licensed professionals;
• our service providers that provide services such as hosting, data analysis, IT services and infrastructure, customer service, e-mail delivery, payment processing, auditing, marketing, advertising and other similar services;
• government agencies, law enforcement, courts and others when we believe in good faith that disclosure is necessary to protect our, your or others’ rights, property, or safety, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law;
• in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.
• to other entities in our corporate family (including SG Medical, P.C. and Virtual Medical Guidance, P.C.)  as necessary for the purposes identified above.
• As described in the Privacy Policy.

How to Exercise Your Rights

The MHMDA and Nevada Consumer Health Data Privacy Law provide certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. 

For details, you can read about the rights granted by the MHMDA at https://app.leg.wa.gov/RCW/default.aspx?cite=19.373.040 and you can read about the rights granted to Nevada residents at https://www.leg.state.nv.us/Session/82nd2023/Bills/SB/SB370_EN.pdf.  Requests to exercise these rights may be sent to privacy@summusglobal.com.

If your request to exercise a right under the MHMDA or Nevada Consumer Health Data Privacy Law is denied, you may appeal that decision by contacting our Privacy Officer at privacy@summusglobal.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Nevada State Attorney at https://ag.nv.gov/Complaints/File_Complaint/ or Washington State Attorney General at https://www.atg.wa.gov/file-complaint, as applicable.