HealthyWage Consumer Health Data Policy

Last modified as of May 24, 2024

Certain U.S. states have laws requiring companies that process data under the broad umbrella term of “consumer health data” (“CHD”) to publish a policy notifying people about how they collect, use, and share (collectively “process” or “processing”) CHD and the rights certain consumers (“Consumer”, “Consumers”, "you", or "your") may have.

This Consumer Health Data Policy (“CHDP” or “Policy”) supplements HealthyWage’’s Privacy Policy and applies solely to Consumers in states with laws pertaining to Consumer Health Data that specifically require such policies. This CHDP applies only to CHD (as defined by applicable law) that is processed by HealthyWage in the course of our business, including via the HealthyWage website, and through our Apps, forums, social media accounts, blogs, and other online or offline offerings (together, with any and all future online and offline offerings operated by or on behalf of HealthyWage, the “Services”).

I.  CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT

As described in the “INFORMATION WE COLLECT" sections of our Privacy Policy, the CHD categories we collect depend on the context of your interactions with HealthyWage, the features you use, the choices you make (including your privacy settings), and applicable law.

CHD is defined broadly, and includes information you may not typically think of as CHD. Many of the categories we collect are, or could be, considered CHD and can be categorized as follows:

• Answers to questions we ask, such as, prior weight loss history, medication usage, weight loss tools/methods.
• Information about your fitness, such as weight data, or step data (if you choose to connect equipment like a step tracker or third party products that facilitate these measurements and collection and sharing of data).
• Pictures (if you choose to upload a profile picture), videos, voice recordings, or physical characteristics that are collected in connection with Services you consent to use; for example, weight verification videos.
• Physical characteristics or descriptions, gender, or inferences based on challenges in which you participate, which may relate to health status.
• Data that helps us serve relevant advertising, and to understand and assess the effectiveness of our ad campaigns.

Other information that is inferred or derived, or may be used to infer or derive data related to the above or other information that could be deemed to be related to health.

II.  SOURCES OF CONSUMER HEALTH DATA

As described further in the “INFORMATION WE COLLECT” section of our Privacy Policy, CHD is sourced in the following manner:

• Directly from you.
• Automatically from your interactions with our products and services
  ◦ Including information we collect, and inferences we make, from your use of HealthyWage Services and from your devices.
• From other sources
  ◦ Including third parties and service providers.

III.  OUR PURPOSES FOR COLLECTING AND USING CONSUMER HEALTH DATA

As described further in the “HOW WE USE PERSONAL INFORMATION” section of our Privacy Policy, we process CHD (collect and use it) as reasonably necessary to provide Services you have requested or authorized. Many of the purposes for which we process data are, or could be, considered processing of CHD and can be categorized as follows:

• Providing, managing, maintaining and improving our Services and their features.
• Personalization and analytics associated with providing Services.
• Personalization associated with advertising.
• Communicating with you for transactional, as well as marketing and promotional, purposes.
• Analytics, including research about how participants utilize our Services to make improvements.
• Other essential business operations that support our Services (such as analyzing our business performance, ensuring security and integrity of our Services, conducting research and development).
• For quality assurance and training purposes.
• Internal purposes such as legal and regulatory compliance, including defending our vital interests.
• Marketing and advertising purposes.

Please see the “HOW TO EXERCISE YOUR RIGHTS & HOW TO SET YOUR DATA PREFERENCES" section of this Policy for information about how you can express your preferences relating to the processing of CHD.

IV.  CATEGORIES OF CONSUMER HEALTH DATA SHARED

We may share each of the categories of CHD described above in the “CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT” section of this Policy. Specifically, we may share CHD with your consent or as reasonably necessary, to provide Services you have requested or authorized. For example, when you make a purchase, we will share information about the transaction as necessary to process the payment, including to protect against fraud. We may disclose CHD when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

For more information about categories of data processed by HealthyWage, please see the “INFORMATION WE COLLECT” sections of our Privacy Policy.

V.  CATEGORIES OF THIRD PARTIES WE SHARE YOUR CONSUMER HEALTH DATA WITH

We may share CHD, with your consent or as reasonably necessary, to provide Services as described in the “OUR PURPOSES FOR COLLECTING AND USING CONSUMER HEALTH DATA” section of this Policy. These are the categories of third parties with whom we may share CHD:

• Service Providers.
  ◦ Vendors or agents (“processors”) working on our behalf may need access to CHD for the purposes described above. For example, vendors who provide IT services, analytics, payment processing, cloud storage, technical support, or delivery services.
• Third Party Apps & Accounts You Link with your HealthyWage Account.
  ◦ As part of our Services, we enable you to connect your Peloton account with third party applications such as Fitbit®, Apple®, and similar applications. If you choose to connect your HealthyWage account, we may share CHD with the paired application depending on what information you choose to share, or have otherwise been notified will be shared during the pairing process.
• Other Users of our Services.
  ◦ Depending on your Profile settings and how you interact with our Services, certain CHD may be available for other participants to see, and certain information may always be viewable.
• Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties.
  ◦ We may disclose CHD 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. In certain circumstances, it may be necessary to provide CHD to other third parties, for example, to comply with the law or to protect our rights or those of our customers, or to detect, prevent, or address security, fraud or technical issues.
• Parties to a corporate transaction (and their agents and advisors).
  ◦ We may disclose CHD 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.

For more information about these categories of third parties, please see the “CIRCUMSTANCES WHEN WE SHARE INFORMATION” section of our Privacy Policy.

VI.  HOW TO EXERCISE YOUR RIGHTS & HOW TO SET YOUR DATA PREFERENCES

Certain U.S. state Consumer Health Data privacy laws provide rights to Consumers, which may include, as applicable, rights to access, delete, or withdraw consent relating to such data, subject to legal limitations and exceptions. Please review the “YOUR RIGHTS TO ACCESS AND CONTROL YOUR PERSONAL DATA” section of our Privacy Policy for detailed information. If you would like to exercise any of your rights, including (in some states) a request to review and request changes to your CHD, please contact us at info@healthywage.com. For additional contact information see the “WHO WE ARE AND HOW YOU CAN REACH US” section of our Privacy Policy.

We verify the requests we receive from you when you exercise certain rights listed above to ensure the safety of your data.

VII. UPDATES TO THIS CONSUMER HEALTH DATA POLICY

We may update this Policy from time to time. When we do, we will provide notice of any material changes if and where this is required by applicable data protection laws. You can see when this CHDP was last updated by checking the "Last Modified Date" displayed at the top of this Policy.

If you have questions, please contact us by calling us at (888) 636-3832 or by emailing us at info@healthywage.com.