This Washington Consumer Health Data Privacy Policy  supplements Venaari LLC’s  general Privacy Policy and describes Venaari’s data collection, processing and sharing practices regarding personal information defined as “consumer health data” subject to the Washington My Health My Data Act when you (whether in your individual or business capacity) access or use our content, products, services or related activities (collectively our “Services”), including through our Internet domains owned or operated by Venaari, which includes https://venaari.com/ (collectively, our “Platform”).

Put more simply, this Consumer Health Data Policy describes our general data practices relating to information that identifies the past, present, or future physical or mental health status of individuals who are state of Washington residents or whose health data is collected in the state of Washington.

Note that this Consumer Health Data Policy does not cover or discuss exempted health data that is subject to other laws, like the federal Health Insurance Portability and Accountability Act (HIPAA) or data that is used for scientific, historical, or statistical research purposes.

Please review this Consumer Health Data Policy carefully. In this Policy, we explain:

• The Consumer Health Data That We Collect
• Why We Collect Consumer Health Data
• How Do We Collect Consumer Health Data
• What Consumer Health Data Is Shared and To Whom
• Your Rights And How To Exercise Them

If you have any questions, please contact us at debra@venaari.com.

The Consumer Health Data That We Collect:

We collect information about individual health conditions, treatment, diseases, and medications as well as non-health data that identifies you as someone who is seeking health care services. This information includes:

• Personal Identifiers, such as your name, address, image, electronic signature, contact information and login and password information; 

• Individual health conditions, treatment, diseases, or diagnosis;
• Social, psychological, behavioral, and medical interventions;
• Health-related surgeries or procedures;
• Bodily functions, vital signs, symptoms, or measurements;
• Diagnoses or diagnostic testing, care instructions, treatment, or medication;
• Gender-affirming care information;
• Reproductive or sexual health information;
• Prescription information, including without limitation, the following: the specific drugs prescribed, the quantity of the drugs prescribed, the dosage of the drugs prescribed, the number of refills of the drugs prescribed, the applicable health care providers, and diagnostic codes;

• Online identifiers, such as unique personal identifiers, device IDs, ad IDs, IP addresses, and cookie data that are gathered as you browse or access our platform;
• Device information such as your device type and operating system, device fingerprint and platform and other technology on the devices you use to access the Platform; 
• Internet, usage, or other electronic network activity information including your time zone setting, auth0 logs, pages visited, pages viewed, events and page loads, session duration and frequency of use, feature usage patterns, notification delivery status and read receipts, network connection type, browser plug-in types and versions; and
• Other health-related information that you choose to provide to us through the Platform.

Why We Collect Consumer Health Data:

We may collect your consumer health data in order to:

• Provide you with the Platform the and health related content that forms our Services to you; 
• Manage, administer and secure your personal account with us;
• Respond to your questions and inquiries;
• Perform data analytics, market research and segmentation;
• Enhance our products and services, including developing new products and services; 

• Comply with law; 
• Work with our service providers who perform certain business functions or services on our behalf;
• Aggregate and deidentify your data; and 
• Verify your identity.

In addition, your consumer health data may be used for internal purposes required for the proper and lawful administration and operation of our business, such as record keeping, auditing, managing our operations and investigating, defending and prosecuting legal claims.

How Do We Collect Consumer Health Data:

We collect consumer health data from: 

• You, directly;
• Referring websites; and 
• Our vendors and service providers.

What Consumer Health Data Is Shared and To Whom:

As a general rule, we only disclose your consumer health information to another entity to receive goods or services consistent with the purposes as disclosed to you in this Consumer Health Data Policy, such as to our vendors or processors. However, there may be times where we may share some or all of the categories of consumer health information described in this Consumer Health Data Policy to non-vendors, as described below:

• As required by law or for legal purposes.  We may disclose some or all of your consumer health data to courts, litigants, regulators, arbitrators, administrative bodies or law enforcement when we have reason to believe that disclosing this information is necessary to comply with law or resolve actual or suspected claims. We may also disclose your consumer health data to identify, contact or bring legal action against someone who may be violating any agreement with us, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures.
• To any third party where you have provided your consent.  Your online browsing data (such as your online identifiers, device information, internet usage, or other electronic network activity) may be provided to third-party analytics providers. If you agree to have your personal information shared with a third party, your personal information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party. 

Your Rights And How To Exercise Them:

Subject to the restrictions in the Washington My Health My Data Act, if you are a Washington state resident or someone whose consumer health data has been collected in Washington state, you may have certain rights with regards to this data. These rights are:

• The right to know whether Venaari  is collecting, sharing, or selling consumer health data concerning you;
• The right to access consumer health data concerning you held by Venaari ;
• The right to be informed of all third parties and Venaari affiliates with whom we have shared or sold your consumer health data (if any) and how to contact these entities;
• The right to withdraw your consent, if previously given, to our collection and sharing of consumer health data concerning you; and
• The right to request that Venaari delete your consumer health data concerning held by us.

Please note that the terms “share” and “sell” have special definitions under Washington My Health My Data Act, which will impact the scope of your rights under this law.

You can submit a request to exercise your rights by e–mailing us directly at  debra@venaari.com.

We will evaluate your request and respond to you. We reserve the right, as allowed by the Washington My Health My Data Act, to authenticate your identity before complying with your request. If your request to exercise a right is denied, you may appeal the denial by responding through the same manner through which we communicated the denial. If your appeal is unsuccessful, you can contact the Washington State Attorney General at https://www.atg.wa.gov/file-complaint to raise an issue or submit a complaint.