Consumer Health Data Privacy Notice

Personify Health, Inc. 

Consumer Health Data Privacy Notice 

Last Updated: November 25, 2025 

This Consumer Health Data Privacy Notice (the “Consumer Health Notice”) supplements the Personify Health General Privacy Notice and explains how Personify Health, Inc. (“Personify Health” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Consumer Health Data (as defined below) of residents of the state of Washington and Nevada through the Personify Health Program (the “Program”). 

Please note that this Consumer Health Privacy Notice does not apply to: 

• Data about our own current and former employees, contractors, agents, and job applicants; 

• Protected health information subject to the Health Insurance Portability and Accountability Act (“HIPAA”);  

• Consumer Health Data that we handle on behalf of and under the instructions of our business customers; and 

• De-identified data. 

This Consumer Health Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law. 

What is Consumer Health Data  

The term “Consumer Health Data” as used in this Consumer Health Privacy Notice means any Consumer Health Data that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, or other applicable state laws governing the use of “consumer health data” (the “Consumer Health Privacy Laws”).  

Collection of Consumer Health Data 

The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, is information that you decide to share with us. This includes information collected through health and wellness journeys and surveys, your communications with us, or from your other interactions with our Program. Consumer Health Data does not include information that is considered de-identified under the Consumer Health Privacy Laws.  

Examples of Consumer Health Data that we may collect include: 

• Information you share about your health-related conditions, symptoms, experiences, diagnoses, testing, or treatments. 

• Measurements such as your height, weight, and blood pressure. 

• Any health-related information that you share with our customer support services. 

• Other information that may be used to infer or derive data related to the above or other health-related information. 

Sources of Consumer Health Data 

We may collect Consumer Health Data you voluntarily provide as you submit it through the web-based platform and the mobile application, by reviewing your use of the web-based platform and mobile application (for example through the completion of a health assessment), your use of a synched tracking device and when you participate in Our phone or on-site services and events. Depending on the Program design chosen by your Program Sponsor, We may collect Consumer Health Data through your use of additional services such as the Personify Health Activity Tracking Devices and the Health Stations (additional information on these is provided in our General Privacy Notice). We may also collect information about you and your participation in the Program through engagement surveys. Depending on your Program design, your Program Sponsor may have the opportunity to create surveys (the “Personify Health Surveys”) for its members to complete. 

For more information about the types of health data we may collect, please review our General Privacy Notice. 

Use of Consumer Health Data 

We may process and/or use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes: 

• To manage and provide the Program. 

• To manage, provide, maintain, and improve the business.  

• To respond to your questions, concerns, and other requests for assistance. 

• To customize your experience in the Program. 

• For providing insights into consumer health behaviors/conditions. 

• To create anonymous, aggregated, or de-identified data 

We may also combine your Consumer Health Data with other Consumer Health Data we collect directly from you or receive from other sources. 

Disclosure of Consumer Health Data 

We may share the categories of Consumer Health Data set forth above as follows: 

• Third-Party Service Providers: We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the operation of the Program. 

• Benefits Distributors and Aggregators. Your Program Sponsor may have engaged Our services through a distributor or aggregator service. We may share limited amounts of Consumer Health Data with these services related to your participation in the Program to facilitate coordination of services across multiple health and wellness providers. 

• Program Partners. We may use or disclose your Consumer Health Data to allow your participation in additional third-party provided wellness services or to support the administration of the Program. These third parties may be Our partners (“Program Partners”), your Program Sponsor, or other entities your Program Sponsor contracts with directly. If your Program Sponsor elects to use a Program Partner, we may share eligibility information in order for the Program Partner to know you are eligible to enroll in their service offering.  If you choose to use Program Partner services or you provide additional Consumer Health Data and data to these Program Partners, you will be subject to the Program Partner’s privacy notice and terms of use.  

• Business Transactions: We may take part in or be involved with a business transaction, such as a merger. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction. We may also disclose Consumer Health Data in the event of a bankruptcy or liquidation.  

• Legal Obligations and Rights: We may disclose Consumer Health Data to third parties: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law. 

Your Privacy Rights 

The Consumer Health Privacy Laws provide the following rights with respect to Consumer Health Data we collect about you:   

• Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.  

• Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.  

• Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.  

How to Exercise Your Privacy Rights 

To exercise any of the privacy rights set forth above or to access or request corrections to your data, please submit a request in our app under “Settings” and “Manage Your Data.” 

Changes to this Consumer Health Notice 

We may update this Consumer Health Notice from time to time. When we make changes to this Consumer Health Notice, we will notify you by changing the date at the beginning of this Consumer Health Notice. If we make material changes to this Consumer Health Notice, we will notify individuals through appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.