Introduction
GoldieCircle LLC (“GoldieCircle,” “we,” “us,” or “our”) is committed to protecting the privacy and security of consumer health data.
What does this Policy cover?
This Consumer Health Data Policy supplements our general Privacy Policy and related disclosures, and applies to personal data defined as “Consumer Health Data” under the privacy laws of certain US states — including Washington’s My Health My Data Act (MHMDA) and Nevada’s health data privacy law (NHDPA). If there is any conflict between this Consumer Health Data Policy and our general Privacy Policy with respect to consumer health data, this Policy controls — except that where our Privacy Policy gives you stronger protection, the stronger protection always applies. Nothing here is intended to reduce a promise we have made you elsewhere.
This Consumer Health Data Privacy Policy describes how we collect, use, disclose, and protect consumer health data in compliance with applicable laws in certain states.
Our Services may contain links to other sites. We do not control these sites and we encourage you to read their privacy notices and consumer health data privacy policies.
Our Services should not be used by individuals who are less than 18 years old.
If you are not comfortable with this consumer health data privacy notice, please reconsider your use of this Site/Service.
What is Consumer Health Data?
“Consumer health data” means personal information that directly or indirectly:
- is linked or reasonably linkable to an identified or identifiable individual; AND
- identifies the individual’s past, present, or future physical or mental health status.
Consumer Health Data We May Collect
Our collection of consumer health data will vary depending on your interactions with us, the Services you utilize, and your preferences and consents. In the course of providing our Services, we may collect or process the following types of consumer health data:
- Individual health conditions, treatment, diseases, or diagnosis
- Social, psychological, behavioral, and medical interventions
- Health-related surgeries or procedures
- Use or purchase of prescribed medication
- Bodily functions, vital signs, symptoms, or measurements of health information
- Diagnoses or diagnostic testing, treatment, or medication
- Gender-affirming care information
- Reproductive or sexual health information
- Precise location information that could reasonably indicate an individual’s attempt to acquire or receive health services or supplies
- Data that identifies an individual seeking health care services
- Information derived or extrapolated from non-health information that is used to identify an individual’s health status
- Other health-related information you may choose to provide to us
- Other information that may be used to infer or derive data related to the above or other health information
YOU ARE PROHIBITED FROM PROVIDING US WITH BIOMETRIC DATA, INCLUDING FACIAL RECOGNITION DATA, AS WELL AS GENETIC DATA.
We do not set out to collect health information, and we encourage you not to share detailed health information through our Services. In practice, health information can reach us in these ways — so you know where to be careful:
- What you type to Goldie. Benefit questions often carry health details (“I’m on dialysis”, “my husband has Alzheimer’s”). Goldie needs enough to point you at the right programs, and no more. She will not give medical advice and is built to redirect health questions to your doctor or pharmacist.
- Documents you upload. A denial letter, an insurance notice, or a medical bill may contain diagnoses, procedures, or medications. We do not keep your document — it is read, explained, and then deleted. See “Documents You Upload” in our Privacy Policy.
- Benefit eligibility screening. Some programs turn on disability status, Medicare enrollment, or medical expenses, so we may ask. Your answers are used to check program rules and to save a profile if you ask us to.
- What you post in the Chatrooms. Rooms such as Health & Wellness, Caregiver Corner, and Grief Support are conversations between members. Anything you post there is visible to other members under your nickname, and rooms are safety-screened. Please treat them as public.
GoldieCircle is not a doctor’s office, hospital, insurer, pharmacy, or health plan. We are not a HIPAA “covered entity” or “business associate,” and information you share with us is not protected health information under HIPAA. It is protected by this policy and by the state health-privacy laws described here. Nothing on GoldieCircle is medical advice.
We will retain and use your consumer health data for the length of time needed to carry out the purposes outlined in this Policy and in accordance with our data retention policies.
How We Use Consumer Health Data
If we collect consumer health data, we use it only for the following purposes:
- Answering what you asked: To respond to your question, explain a document you uploaded, or check which benefit programs you may qualify for
- Service Provision: To provide and maintain our Services
- Communication: To respond to your inquiries and provide customer support
- Legal Compliance: To comply with applicable laws and legal obligations
- Safety and Security: To protect the safety, security, and integrity of our Services, including responding when someone may be at risk of harm
- Research and Analytics: For internal research, analytics, and development purposes, in aggregated or de-identified form
We do not use, share, or sell consumer health data for advertising or marketing — not our own, and not anyone else’s. We do not build health-based advertising profiles, we do not target ads to you based on a health condition, medication, or anything you have told Goldie or uploaded to the Document Helper, and we do not sell consumer health data to anyone, for any price. Advertising on GoldieCircle is chosen from the page you are reading and your general area — never from your health.
Goldie’s memory is deliberately built to keep health out of it. The system that writes those short summaries is instructed never to record diagnoses, medications, symptoms, treatments, or mental-health descriptions, and it additionally screens its own output for that kind of language and discards it. Everyday life events are kept (“lost her husband last spring”); health facts are not (“has dementia”, “takes blood pressure medicine”). No automated system is perfect, so please still avoid sharing health details you would want kept completely private.
How We Share Consumer Health Data
We may share consumer health data specified above with your consent, and as is reasonably necessary for other legitimate purposes.
Service Providers
We may share consumer health data with service providers who perform services on our behalf, such as:
- Cloud hosting and infrastructure providers
- Analytics and data processing services
- Customer support platforms
- AI model providers (only as necessary to provide Services)
All service providers are contractually required to:
- Use consumer health data only for specified purposes
- Implement appropriate security measures
- Comply with applicable health data privacy laws
- Not further disclose the data except as necessary to provide services
Business Partners
We do not share consumer health data with business partners for their own purposes, and we do not sell it. If that were ever to change, we would first obtain your separate, affirmative, written authorization for the specific purpose — as required by the My Health My Data Act — and you could refuse or withdraw it at any time without losing access to our Services.
Organizations You Ask Us to Contact
If you ask us to put you in touch with a specific organization — a senior center, a housing program, an area agency on aging — we pass on what is needed for them to help you. That happens because you asked, and only then.
Legal Requirements
We may disclose consumer health data:
- To comply with valid legal process (court orders, subpoenas, search warrants)
- To respond to lawful government or law enforcement requests
- To protect against fraud, security threats, or illegal activity
- To defend our legal rights or enforce our terms
- As required or permitted by applicable law
Geofencing — We Don’t Do It
GoldieCircle does not use geofencing or location-based advertising within 2,000 feet of any healthcare facility, mental health provider, reproductive health clinic, substance-use treatment center, or other sensitive location. We do not deliver advertisements, gather data, or send health-related messages based on your physical proximity to such facilities. This affirmative statement is made in compliance with Washington State’s My Health My Data Act (MHMDA) and similar laws.
De-identified or Aggregated Data
We may share aggregated, de-identified, or anonymized health data that cannot reasonably identify individuals, without restriction.
Your Rights Regarding Consumer Health Data
If you are covered by the MHMDA, the NHDPA, or other applicable consumer health privacy law, then you may have certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights by contacting us at [email protected].
Please note that, as permitted or required under applicable law, we take steps to verify your request before processing it. If further information is needed to verify your request, we may ask you to provide additional details. We will respond to verified requests within the timeframes required by applicable law (up to 90 days).
In some instances, we may be unable to fulfill your request. If your rights request is denied, applicable law may entitle you to appeal with us. The response to your rights request will outline any appeal rights you may have and explain how to exercise them.
Contact Us
If you have questions, concerns, complaints, or requests regarding this Consumer Health Data Privacy Policy, please contact us:
GoldieCircle LLC
Email: [email protected] · [email protected]
Mail: GoldieCircle LLC, Attn: Privacy Department, 8 The Green, Suite B, Dover, DE 19901
Changes to This Health Policy
We reserve the right to update this Consumer Health Data Policy from time to time to reflect:
- Changes in our data practices
- New legal requirements
- Feedback from users or regulators
Revisions to this Policy may occur at any time, and when we make material changes, we will:
- Update the “Last Updated” date
- Post the revised policy on our website