Health Data Policy

Consumer Health Data Privacy Notice

Last Updated: April 16, 2025

Fillow, Inc., a Delaware corporation (“Fillow”) is committed to respecting your privacy. Our website Privacy Policy describes how we handle your personal information generally. This supplemental Consumer Health Data Privacy Policy (“Health Privacy Notice”) explains our practices for “Consumer Health Data” as such term is defined by applicable laws (“U.S. Health Privacy Laws”).

If we make any material updates to this Health Privacy Notice, we will notify you as required by U.S. Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Notice. We reserve the right to amend this Health Privacy Notice at our discretion and at any time. 

1.      Definitions

The term “Consumer Health Data” is defined to mean personal information that is linked or can be reasonably linked to a consumer and that that identifies past, present or future physical or mental health status, and includes the following: information about medical conditions as well as non-medical information, and information about use of non-prescription medication or use of health-related products.

The term Consumer Health Data does not include deidentified data or information pertaining to individuals with whom we have an employment relationship.

2.     Categories of Consumer Health Data that We Collect

Fillow shall collect, use, and disclose Consumer Health Data as needed to provide or otherwise facilitate the products or services that you request or with your consent. We may collect Consumer Health Data related to the following categories of Consumer Health Data:

3.     Prohibited Data

You are hereby prohibited from providing us with the following data:

·       Biometric Data. Information including facial recognition data, and a mathematical representation of your biometric identifier, such as the template maintained for comparison.

·       Genetic Information. Information that concerns your genetic characteristics, such as information revealed by analyzing DNA sequences or familial genetic information.

4.     Purposes for Collecting Consumer Health Data and How We Use It

We may, from time to time, use your Consumer Health Data for the following purposes:

5.     Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

·       From you, such as when you engage with us about an adverse event that occurred from using our products.

·       We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.

6.     Disclosures of Consumer Health Data

We do not, to the best of our knowledge “sell” or “share” your Consumer Health Data, as such terms are defined pursuant to U.S. Health Privacy Laws. However, we may disclose the categories of Consumer Health Data described above in the following circumstances:

·       We may disclose Consumer Health Data with our data processors, service providers and contractors who assist us in providing goods and services to you. These processors may only use the data as directed by us or permitted by our contracts with them.

·       We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or a transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.

7.     Your Privacy Rights

Depending on the jurisdiction in which you reside, you have specific rights with respect to your Consumer Health Data:

·       You have the right to know if we are collecting, using or disclosing your Consumer Health Data, to access your Consumer Health Data.

·       You have the right to confirm whether we are sharing or selling your Consumer Health Data, including receiving a list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data and an active email address or other online mechanism that you may use to contact these third parties.

·       You have the right to request that we delete your Consumer Health Data.

·       If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services.

To exercise these rights, please contact us in accordance with the “Contact Us” section below. Once you submit such a request, we will authenticate your requests and process it as required by law. Please allow up to 45 days for a response.

8.     Appeals and Complaints

If we deny your privacy rights request, you may appeal that denial by undertaking the following, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review.

You may also file a complaint with the relevant state regulatory agency, including:

·       Washington State Attorney General at www.atg.wa.gov/file-complaint.

·       Nevada Attorney General at https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/.

·       Connecticut Attorney General at https://portal.ct.gov/ag/common/complaint-form-landing-page.

9.     Contact Us

For the avoidance of your doubt, you may not, under any condition, upload or otherwise input into our website (whether via a chat-box, interactive form, or other online communication platform) with any Consumer Health Data whatsoever.

If you have any questions or concerns about this Health Privacy Notice, or would like to exercise a right set forth herein, please contact us at: (email) hello@fillowme.com , (mail) Fillow, ATTN: Privacy Rights, 666 Dundee Road, Suite 1703, Northbrook, IL 60062.