Consumer Health Data Privacy Policy

Healthful Data, Inc.

JoinHealthful.com | Thrive.JoinHealthful.com | HealthfulData.com

Effective Date: October 26, 2026

This Consumer Health Data Privacy Policy (“Consumer Health Policy”) supplements Healthful Data, Inc.’s general Privacy Policy and applies only to “consumer health data” collected, used, shared, sold, disclosed, or otherwise processed by Healthful Data, Inc. (“Healthful Data,” “HDI,” “we,” “us,” or “our”) through JoinHealthful.com, Thrive.JoinHealthful.com, HealthfulData.com, related assessments, surveys, reports, applications, and services.

For purposes of this Policy, “consumer health data” means personal information that is linked or reasonably linkable to an individual and identifies the individual’s past, present, or future physical or mental health status.

If this Consumer Health Policy conflicts with our general Privacy Policy, this Consumer Health Policy will control with respect to consumer health data.

Contact Information

Privacy Officer
Healthful Data, Inc.
900 108th Avenue NE #506
Bellevue, WA 98004

Email: privacy@joinhealthful.com

Telephone: 617-997-8674

Categories of Consumer Health Data We Collect

We collect consumer health data that you voluntarily choose to provide, including:

• Current, past, suspected, self-diagnosed, or physician-diagnosed health conditions.
• Symptoms and health concerns.
• Medical history.
• Treatment, medication, device, and therapy experiences.
• Health care utilization and provider experiences.
• Family health history.
• Lifestyle and wellness information.
• Caregiving experiences relating to another individual’s health condition.
• Information identifying you as seeking, obtaining, researching, or receiving health care services.
• Survey responses, assessment responses, interview responses, and research responses.
• Audio recordings, video recordings, photographs, written statements, transcripts, and stories discussing health conditions or health experiences.
• Information regarding disability, chronic illness, disease progression, quality of life, treatment outcomes, or patient experiences.
• Any other health-related information you voluntarily submit through our Services.

Categories of Sources From Which We Collect Consumer Health Data

We collect consumer health data from:

• You directly through surveys, forms, assessments, interviews, questionnaires, reports, contests, promotions, and account registration.
• Information you upload through JoinHealthful.com, Thrive.JoinHealthful.com, or HealthfulData.com.
• Information submitted through customer support interactions.
• Information submitted through optional research participation.
• Authentication providers that you choose to use (for example, Google sign-in).
• Authorized representatives acting on your behalf.

We do not knowingly collect consumer health data from children under thirteen (13) years of age.

Why We Collect Consumer Health Data

We collect consumer health data to:

• Create Healthful Stories™ and Healthful Data™ content.
• Generate HealthRank Insights Reports™ and other participant reports.
• Conduct Healthful Assessments™.
• Operate and improve our Services.
• Analyze trends relating to health conditions and patient experiences.
• Conduct, support, or facilitate scientific, academic, and health policy research.
• Produce aggregate and de-identified reports.
• Develop educational materials.
• Conduct quality assurance and system administration.
• Communicate with users regarding participation, reports, and services.
• Comply with legal obligations.
• Protect the security and integrity of our systems.
• Any additional purpose for which you provide separate consent.

Categories of Consumer Health Data We Share

Subject to applicable law and your consent where required, we may share:

• Health conditions and diagnoses.
• Symptoms and disease experiences.
• Treatment experiences.
• Survey and assessment responses.
• Audio, video, image, transcript, and written health-related content.
• Healthful Stories™ submitted by users.
• Demographic information associated with health information.
• Information voluntarily made public by users.
• De-identified and aggregated health information.

Categories of Third Parties With Whom We Share Consumer Health Data

We may share consumer health data with:

Service Providers

Companies that help us:

• Host our systems.
• Store data.
• Process surveys.
• Provide analytics.
• Manage communications.
• Provide customer support.

Research Organizations

• Universities.
• Academic researchers.
• Research institutions.
• Scientific publishers.

Health Care Stakeholders

• Nonprofit organizations.
• Patient advocacy organizations.
• Health policy organizations.
• Government agencies where required by law.

Professional Advisors

• Legal counsel.
• Auditors.
• Compliance providers.

Successors

• Acquiring entities in connection with a merger, acquisition, reorganization, or asset sale.

Public Audiences

Where you voluntarily elect to publish your Healthful Story™, content may become available to the public.

Specific Affiliates

Consumer health data may be shared with:

• Healthful Data, Inc.

As of the Effective Date, Healthful Data, Inc. does not maintain additional affiliated entities receiving consumer health data.

If additional affiliates begin receiving consumer health data, this Policy will be updated accordingly.

Sale of Consumer Health Data

Healthful Data, Inc. does not sell consumer health data unless separate authorization is obtained where required by applicable law.

Where required by law, any sale of consumer health data will occur only after obtaining valid authorization containing all legally required disclosures.

Your Privacy Rights

Subject to verification and applicable law, you may have the right to:

Access

Confirm whether we collect, use, share, or sell your consumer health data and obtain access to that information.

Deletion

Request deletion of your consumer health data.

Withdrawal of Consent

Withdraw consent for collection or sharing of consumer health data where consent is the legal basis for processing.

List of Third Parties

Request a list of affiliates and third parties with whom we have shared your consumer health data.

Appeal

Appeal a decision denying a privacy rights request.

Nondiscrimination

Exercise your privacy rights without unlawful discrimination.

How To Exercise Your Rights

To submit a request:

Email: privacy@joinhealthful.com

Mail:

Healthful Data, Inc.
Attn: Privacy Officer
900 108th Avenue NE #506
Bellevue, WA 98004

We may request information sufficient to verify your identity before processing a request.

You may also designate an authorized agent to act on your behalf where permitted by law.

Research, De-identified Data, and Aggregate Data

Healthful Data, Inc. may create:

• Aggregate Information
• De-identified Information
• Statistical Information
• Research Datasets

from consumer health data.

Such information may be used for:

• Scientific publication.
• Research purposes.
• Public health purposes.
• Educational purposes.
• Product development.
• Policy analysis.

We will take reasonable measures intended to prevent re-identification of de-identified information.

Security

We maintain administrative, technical, and physical safeguards designed to protect consumer health data.

However, no method of electronic transmission or storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

Retention

We retain consumer health data for as long as reasonably necessary to:

• Provide Services.
• Conduct research.
• Comply with legal obligations.
• Resolve disputes.
• Enforce agreements.
• Achieve the purposes described in this Policy.

Retention periods may vary based on the type of information involved.

Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time.

Material changes will be posted with an updated Effective Date.

Washington Residents

If you are a Washington resident, this Consumer Health Data Privacy Policy is intended to supplement disclosures required by the Washington My Health My Data Act.

Nevada Residents

If you are a Nevada resident, additional rights may apply under Nevada consumer health data laws.

We do not use geofencing technologies to identify, track, collect consumer health data from, or send communications to consumers based upon visits to health care facilities.

Connecticut Residents

If you are a Connecticut resident, additional rights may apply under the Connecticut Data Privacy Act and related provisions governing sensitive personal data and consumer health information.

Questions

For questions regarding this Consumer Health Data Privacy Policy, contact:

Healthful Data, Inc.
Privacy Officer
900 108th Avenue NE #506
Bellevue, WA 98004

Email: privacy@joinhealthful.com
Phone: 617-997-8674