Consumer Health Data Privacy Policy

Effective date: April 1, 2025

This Consumer Health Data Privacy Policy (“Health Privacy Policy”) applies to ProDx Health’s collection of “Consumer Health Data” (described below) of consumers that reside in certain states such as Connecticut, Washington, or Nevada (“you”) in accordance with the Connecticut Data Privacy Act, Nevada’s Consumer Health Data Privacy Law, and the Washington My Health My Data Act (each as applicable, the “Consumer Health Data Privacy Laws”). This Health Policy supplements ProDx Health’s Privacy Policy, and any capitalized but not defined terms in this Health Privacy Policy will have the definitions set forth in ProDx Health’s Privacy Policy or the applicable Consumer Health Data Privacy Law.

Collection of Consumer Health Data

“Consumer Health Data” generally includes personal information that is linked or reasonably linkable to you and that identifies, or that ProDx Health may use to identify your past, present, or future physical or mental health status. Consumer Health Data does not include information that is publicly available, de-identified, or aggregated.

Categories of Consumer Health Data We Collect

The Consumer Health Data we collect may include information about a health or wellness condition that you provide to us, such as:

  • Information provided in a questionnaire or survey

  • Data related to your use of ProDx Health’s at-home health test kits (e.g., STD testing kits, hormone health kits)

  • Results and reports generated from lab testing and analysis

Our Purposes for Collecting and Using Consumer Health Data

We may collect, use, disclose, or otherwise process your Consumer Health Data as reasonably necessary to provide you with products or services relevant to your Consumer Health Data. This includes:

  • Delivering at-home health test kits and related services

  • Processing and analyzing test results

  • Providing reports through your online account or email

  • Ensuring compliance with legal and regulatory requirements

We do not engage in geofencing around our stores that provides in-person health care services in Washington to either:

  1. Identify or track you when seeking health care services

  2. Collect your Consumer Health Data

  3. Send notifications, messages, or advertisements related to your Consumer Health Data or health care services.

We may create aggregated, de-identified, or anonymized data from the Consumer Health Data we collect, including by removing information that makes the data personally identifiable to you. We may use such aggregated, de-identified, or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

We do not “sell” your Consumer Health Data as defined under Health Data Privacy Laws.

How We Disclose Your Consumer Health Data

We may disclose your Consumer Health Data as reasonably necessary to Third Parties and Affiliates, which may include:

  • Vendors: Service providers, contractors, analytics partners, business partners, and vendors to provide and improve our Services to you.

  • Other Parties: Those to whom you have explicitly given consent for disclosure.

Additionally, we may disclose your Consumer Health Data in the following ways:

  • To government entities, including law enforcement, to meet legal requirements and enforce legal terms.

  • During transactions such as mergers, acquisitions, bankruptcies, or other events in which a third party assumes control of our business.

Consumer Health Data Rights

If we have collected your Consumer Health Data, you may have rights depending on the applicable Consumer Health Data Privacy Law, which also may be subject to certain requirements and exceptions. These rights include:

Access and Portability

  • Washington and Nevada Residents: Right to request a list of all third parties and affiliates with whom we have disclosed or sold your Consumer Health Data and their contact information, if applicable.

  • Connecticut Residents: Right to request a copy of your Consumer Health Data in a machine-readable format, to the extent technically feasible.

Correction

  • Connecticut Residents: Right to correct inaccuracies in your Consumer Health Data, depending on the nature of such data and our processing purposes.

Deletion

  • You have the right to request that we delete the Consumer Health Data that we have collected about you.

Withdraw Consent

  • You have the right to withdraw consent from us collecting and disclosing your Consumer Health Data. This may require the deletion of your Personal Data or account with us.

Opt-Out of Sale, Targeted Advertising, and Profiling

  • Connecticut Residents: Right to opt-out of the sale and/or processing of your Consumer Health Data for targeted advertising and profiling purposes. However, we do not conduct such activities.

Nondiscrimination

  • We will not discriminate against you for exercising your rights as described above.

Appeal

  • If we refuse to act on your request, you may appeal our decision. If we deny your appeal, you have the right to contact the Attorney General of your state of residence (NV, WA, CT).

How to Exercise Your Rights

To exercise your rights, you must submit a request that:

  1. Provides sufficient information for us to verify your identity and relationship with us.

  2. Describes your request in sufficient detail to allow us to understand, evaluate, and respond.

Each request that meets these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria.

You may submit a Valid Request by using the following methods:

If you have any questions or concerns about this policy or your rights, please contact us at support@prodxhealth.com. We will not discriminate against you for exercising your rights under applicable law.