LENUS CONSUMER HEALTH DATA PRIVACY POLICY

INTRODUCTION

Lenus eHealth Inc. (“Lenus,” “we,” “us,” and “our”) is committed to respecting your privacy.  This Consumer Health Data Privacy Policy supplements the Lenus Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act.

CONSUMER HEALTH DATA COLLECTED

Consumer health data means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. The consumer health data we collect depends on the context of your interaction with us. Examples of consumer health data we may collect in the course of providing our services include information about an individual’s:

• health conditions, treatment, diseases, or diagnoses;
• social, psychological, behavioral, and medical interventions;
• use or purchase of medications or prescribed medications;
• bodily functions, vital signs, symptoms, or measurements of health information;
• diagnoses or diagnostic testing, treatment, or medication;
• biometric data; or 
• information that could identify an attempt to seek health care services or information.

SOURCES OF CONSUMER HEALTH DATA

We collect consumer health data from the following sources:

• Directly from you when you interact with us or use our services;
• Automatically through cookies and other tracking technologies; or
• From third parties such as coaches, healthcare providers, and pharmacies.

PURPOSES FOR COLLECTION AND USE

Our collection of consumer health data is incidental to the provision of our services. We may use consumer health data to compile analytics, conduct research, improve our services, and comply with legal and regulatory obligations, for any other purpose with your consent, or otherwise as described in the Lenus Privacy Policy.

DISCLOSURE OF CONSUMER HEALTH DATA

We may disclose consumer health data to our service providers and business partners (including coaches and healthcare providers) so that they can help us provide our products, services, and programs. With your consent, we may also disclose consumer health data to other recipients. 

We may disclose consumer health data to our affiliate(s), Lenus eHealth ApS‍.

We may also disclose consumer health data to a successor in interest in the event of a corporate transaction such as a merger or acquisition or other corporate restructuring. In addition, we may disclose consumer health data to government agencies or otherwise as necessary to comply with law or prevent, detect, or investigate fraud or threats to health, safety, or legal rights.

YOUR RIGHTS

Washington residents have the following rights with respect to their consumer health data, subject to certain exceptions:

• the right to confirm whether we process your consumer health data, and to access and receive a copy of your consumer health data;
• the right to a list of all third parties and affiliates with whom we have shared or sold your consumer health data and an email address or other online mechanism that you can use to contact each third party;
• the right to delete your consumer health data; and
• the right to withdraw consent to the collection, sharing, or selling of consumer health data.

You can submit a request to exercise these rights using any of the mechanisms listed in the Contact Information section below.  Depending on the type of request, we may need to verify your request before we can fulfill it. Please note that certain exceptions may apply to these rights. Finally, please review the Lenus Privacy Policy for additional rights and choices you may have with respect to your personal data more generally.

You have the right to appeal any decisions we make in response to your rights request. 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.

CHANGES TO THIS POLICY

We may revise this policy from time to time. When we make changes to this policy, we will post the updated version on our website and indicate the date the policy was last updated. We encourage you to review this policy periodically to check for any updates. 

CONTACT INFORMATION

If you have any questions about this policy or if you would like to exercise your privacy rights, please contact us at privacy@lenus.io, 895 Broadway, 5th Floor, New York, NY 10003, United States, or online at https://www.lenusehealth.com/contact. 

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SUPPLEMENT TO CONSUMER HEALTH DATA PRIVACY POLICY FOR NEVADA CONSUMERS

This supplement to our Consumer Health Data Privacy Policy applies to Nevada residents for purposes of providing additional disclosures required by Nevada’s consumer health data privacy law (Nevada Senate Bill 370).

The foregoing consumer health data disclosures and rights also apply to Nevada residents. In addition, Nevada residents also have the right to review and amend any consumer health data we maintain about them. Nevada residents can escalate unsuccessful appeals of consumer rights requests to the Nevada attorney general at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/. Third parties may collect consumer health data over time and across different websites when you use our websites in Washington and Nevada. 

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