Washington Consumer Health Data Privacy Policy

Healthful Data, Inc.

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

Effective Date: October 26, 2026

IMPORTANT NOTICE

This Consumer Health Data Privacy Policy applies only to Washington consumers and only to consumer health data governed by Washington’s My Health My Data Act (“MHMDA”).

This Policy supplements Healthful Data, Inc.’s general Privacy Policy and Terms of Use. If there is a conflict between this Policy and our general Privacy Policy regarding consumer health data, this Policy controls.

For purposes of this Policy:

• “Consumer Health Data” has the meaning provided under the Washington My Health My Data Act.
• “Healthful Data,” “HDI,” “we,” “our,” or “us” means Healthful Data, Inc.
• “Services” includes JoinHealthful.com, Thrive.JoinHealthful.com, HealthfulData.com, Healthful Assessments™, HealthRank Insights Reports™, CLCBI assessments, surveys, research activities, reports, applications, and related services.

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 may collect the following categories of Consumer Health Data that you voluntarily choose to provide:

• Health conditions, diagnoses, diseases, disorders, illnesses, symptoms, and medical concerns.
• Suspected, self-reported, or physician-diagnosed health conditions.
• Treatment, medication, therapy, device, and healthcare experiences.
• Health outcomes and quality-of-life information.
• Family health history.
• Caregiver experiences relating to another person’s health condition.
• Demographic information when associated with health information.
• Lifestyle, wellness, behavioral, and health-related information.
• Information identifying you as seeking, researching, obtaining, considering, or receiving healthcare services.
• Information identifying participation in health-related assessments, surveys, studies, or research.
• Healthful Assessment™ responses.
• HealthRank Insights Report™ responses and results.
• CLCBI responses and results.
• Audio recordings, video recordings, photographs, images, transcripts, written narratives, and Healthful Stories™ discussing health-related topics.
• Other information that may identify your past, present, or future physical or mental health status.

Purposes for Collection and Use

We collect and use Consumer Health Data for the following purposes:

• Creating HealthRank Insights Reports™ and related participant reports.
• Conducting Healthful Assessments™ and surveys.
• Creating, publishing, and analyzing Healthful Stories™.
• Operating, improving, securing, and administering our Services.
• Producing de-identified and aggregate analyses.
• Conducting scientific, academic, public-health, and health-policy research.
• Creating publications, reports, benchmarking tools, and educational materials.
• Informing policymakers, researchers, healthcare stakeholders, nonprofit organizations, advocacy groups, healthcare organizations, and other interested parties.
• Developing products, services, analytics, intellectual property, and research findings.
• Communicating with participants regarding their participation, reports, research opportunities, and services.
• Fulfilling any purpose for which you separately provide consent.

Categories of Sources From Which We Collect Consumer Health Data

We collect Consumer Health Data from the following categories of sources:

• Directly from you through surveys, assessments, interviews, questionnaires, forms, registrations, uploads, stories, research participation, and reports.
• Information submitted through your Healthful Member™ account.
• Customer service and support communications.
• Information submitted by a legally authorized representative acting on your behalf.
• Third-party authentication providers you choose to use, such as Google sign-in.

Categories of Consumer Health Data We Share

Subject to applicable law and any required consent or authorization, we may share:

• Health conditions, diagnoses, symptoms, and disease experiences.
• Health assessment responses.
• Research responses.
• Treatment and care experiences.
• Healthful Stories™ and related content.
• Audio, video, images, photographs, transcripts, narratives, and written statements.
• Information that identifies you when you choose to make your story public or otherwise authorize such disclosure.
• De-identified and aggregate information derived from Consumer Health Data.

Categories of Third Parties With Whom We Share Consumer Health Data

We may share Consumer Health Data with the following categories of third parties:

Service Providers and Processors

Companies that provide:

• Cloud hosting
• Data storage
• Security services
• Analytics
• Communications services
• Technical support
• Survey administration
• Research support

Researchers and Research Organizations

• Universities
• Academic institutions
• Research organizations
• Scientific publishers
• Research collaborators

Healthcare and Public Policy Organizations

• Healthcare organizations
• Patient advocacy groups
• Disease foundations
• Nonprofit organizations
• Public-health organizations
• Policymakers and governmental bodies

Professional Advisors

• Attorneys
• Auditors
• Compliance consultants

Business Partners and Sponsors

Organizations participating in specific studies, assessments, reports, surveys, or initiatives where sharing is authorized by law and any required consent has been obtained.

The Public

Information may be shared publicly where you choose to make your Healthful Story™, interview, content, or related information public.

Specific Affiliates

As of the Effective Date of this Policy, Consumer Health Data may be shared with the following affiliated entity:

• Healthful Data, Inc.

At present, Healthful Data, Inc. does not identify additional affiliated entities receiving Consumer Health Data.

Should additional affiliates receive Consumer Health Data, this Policy will be updated accordingly.

Commercialization of Data, Research, and Analytics

Healthful Data’s mission includes creating research, reports, benchmarking tools, analytics, publications, datasets, and healthcare insights.

Accordingly, Healthful Data may create, license, distribute, publish, sell, commercialize, or otherwise provide:

• Aggregate information;
• De-identified information;
• Research datasets;
• Benchmarking datasets;
• Statistical analyses;
• Reports;
• Publications;
• Research findings;
• Derivative works; and
• Other information products derived from information contributed by participants.

As described in our Privacy Policy and Terms of Use, Healthful Data may generate intellectual property, products, services, publications, and commercial offerings from contributed information.

Unless otherwise agreed in writing, participants will not receive compensation arising from such commercialization.

Sale of Consumer Health Data

Healthful Data may commercialize aggregate, de-identified, statistical, and research information derived from participant-contributed information.

Healthful Data will not sell Consumer Health Data that remains linked or reasonably linkable to an identified or identifiable individual without obtaining any consent or authorization required by applicable law.

Where Washington law requires authorization for the sale of Consumer Health Data, Healthful Data will obtain such authorization before the sale occurs.

Your Rights Under Washington’s My Health My Data Act

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

Access and Confirmation

Confirm whether Healthful Data is collecting, sharing, or selling your Consumer Health Data and access such information.

List of Third Parties

Receive a list of affiliates and third parties with whom Consumer Health Data has been shared or sold, together with an active email address or other online mechanism enabling contact with such parties.

Withdrawal of Consent

Withdraw consent previously provided for the collection or sharing of Consumer Health Data.

Deletion

Request deletion of your Consumer Health Data.

Where required by law, Healthful Data will delete Consumer Health Data from its records and notify processors, contractors, affiliates, and other applicable third parties to delete the information as required.

Appeal

Appeal a denial of a Consumer Health Data rights request.

Nondiscrimination

Exercise your rights without unlawful discrimination, retaliation, or penalty.

How to Exercise Your Rights

To submit a Consumer Health Data request:

Email: privacy@joinhealthful.com

Mail:

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

We may require information reasonably necessary to verify your identity before responding to your request.

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

Security

We maintain administrative, technical, and physical safeguards intended to protect Consumer Health Data.

However, no system can guarantee absolute security, and no security measures can eliminate all risks of unauthorized access or disclosure.

Changes to This Policy

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

Material changes will be reflected by posting an updated version with a revised Effective Date.

Washington-Only Applicability

This Policy applies exclusively to Washington consumers and Consumer Health Data governed by Washington’s My Health My Data Act.

For residents of other states, please refer to the Healthful Data Privacy Policy and any applicable state-specific consumer privacy disclosures.

Contact

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

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

Effective Date: October 26, 2026