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Consumer Health Data Privacy Policy

Last Updated: 12/11/2024

HeroGeneration (“we,” “us,” “our,” or “HeroGeneration”) values your privacy. This Consumer Health Data Privacy Policy (the “Policy”) applies to our collection, use and disclosure of “consumer health data” as defined by the Washington My Health My Data Act (“MHMDA”), the Nevada Consumer Health Data Privacy Act (“NCHDPA”), the Connecticut Data Privacy Act (“CDPA”) or other US health privacy laws when you visit our website or use HeroGeneration or our services (“Services”). This Policy supplements our general Privacy Policy.

This Policy describes the categories of consumer health data we collect; the purposes for which we collect and use consumer health data; the categories of sources from which we collect consumer health data; the categories of consumer health data we share; the third parties with whom we share consumer health data; and how you can exercise your rights with respect to your consumer health data.

We reserve the right to update or modify this Policy at any time in our sole discretion, including without limitation, in order to comply with applicable law, and will post the effective date of any updates or modifications at the top of this Policy.

Consumer Health Data We Collect

When you use our Services we will collect the following consumer health data that you provide:

  • individual health conditions, treatment, diseases, or diagnosis;
  • social, psychological, behavioral, and medical interventions;
  • health-related surgeries or procedures;
  • use or purchase of prescribed medication;
  • bodily functions, vital signs, symptoms, or measurements;
  • diagnoses or diagnostic testing, treatment, or medication;
  • gender-affirming care information;
  • reproductive or sexual health information;
  • genetic data;
  • data that identifies you as a consumer seeking health care services; or
  • any information that we or our processor(s) may use to associate or identify you with the data described above that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning).

Purposes of Collecting and Using Consumer Health Data

We may collect and use consumer health data to:

  • create and manage your account with us;
  • offer and provide products and services to you;
  • communicate with you about, and enable you to participate in, surveys, events, and programs;
  • process claims we receive in connection with our products and services;
  • manage, operate, and improve our business;
  • respond to your communications, inquiries, and requests;
  • provide customer support, including diagnosing and fixing technical issues;
  • perform data analyses (including, without limitation, market and consumer research, trend analysis, financial analysis, and anonymization);
  • display content on the Services and tailor and customize your use of the Services to meet your needs, such as by saving your preferences;
  • identify and gather demographic and usage information about our users to tailor the Services to better meet the needs of our users;
  • protect against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and
  • comply with and enforce applicable legal requirements, relevant industry standards and our contractual rights and policies.

Sources from Which We Collect Consumer Health Data

We only collect consumer health data directly from you or directly via the Services from other individuals who you have authorized to share your consumer health data.

Third Parties with Whom We Share Consumer Health Data

We may share consumer health data with the following third parties:

  • any user of the Services with whom you have authorized us to share your consumer health data;
  • our affiliates and subsidiaries;
  • third-party business partners and vendors who perform services on our behalf solely to the extent needed to provide such services and subject to an agreement which restricts their usage;
  • governmental authorities, where such sharing is:
    • required by law or legal process, such as in response to a valid court order or subpoena;
    • in response to a government request or law enforcement investigation;
    • intended to exercise or defend our legal rights; or
    • necessary or appropriate to prevent physical harm or suspected or illegal activity; or
  • successor entities to whom we may transfer your consumer health data information in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).

Your Rights and Choices

You have the following rights and choices with respect to your consumer health data:

  • right to know what consumer health data we collect, share, or sell, including a list of all third parties and affiliates with whom we have shared or sold consumer health data and an active email address or other online mechanism that you may use to contact these third parties;
  • right to withdraw consent to our collection and sharing of your consumer health data;
  • right to request deletion of your consumer health data; and
  • right to appeal any refusal by us to take action on your request within a reasonable period of time after your receipt of our decision.

To make a request with respect to your consumer health data, please email us at hello@herogeneration.co.

To protect your privacy and security, we must authenticate your identity prior to completing any request that you may submit with respect to your consumer health data. We will authenticate your identity by asking you to provide certain information that we have already collected from you to confirm that it matches our records.

You have the right to two requests per year free of charge with respect to your consumer health data. We may charge a reasonable fee for any additional requests or requests that are manifestly unfounded, excessive, or repetitive.

You have the right to appeal any refusal by us to take action on your request within a reasonable period of time after your receipt of our decision. To appeal such refusals, please email us at hello@herogeneration.co. You may also file a complaint with the relevant government body in your state. If you are a Washington resident, you may file a complaint with the Washington State Attorney General by following the procedures set forth on the Attorney General's website found here: https://www.atg.wa.gov/file-complaint. If you are a Nevada resident, you may file a complaint with the Nevada State Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/.

Updates to the Consumer Health Data Privacy Policy

We may update this Policy at any time and without prior notice to you to reflect any changes to our information practices or to comply with applicable laws or regulations. We will post a notice on our website to notify you of any significant changes to this Policy and indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any comments or questions about this Policy or our consumer health data practices, please contact us by email at hello@herogeneration.co.