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 disclosure, and applies to personal data defined as “Consumer Health Data” under privacy laws of certain US states. If there is any conflict between this Consumer Health Data Policy and our general Privacy Policy, this Consumer Health Data Policy will control with respect to consumer health data.

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

We do not intentionally collect sensitive health information, and we encourage users not to share detailed health information through our Services.

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 may use it for the following purposes:

• Service Provision: To provide, maintain, and improve our Services
• Personalization: To personalize your experience and tailor recommendations
• Communication: To respond to your inquiries and provide customer support
• Marketing: Conducting advertising and other marketing activities, both for our Services and other third parties’ products or services we believe may interest you
• Legal Compliance: To comply with applicable laws and legal obligations
• Safety and Security: To protect the safety, security, and integrity of our Services
• Research and Analytics: For internal research, analytics, and development purposes (in aggregated or de-identified form)

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 (With Consent)

We may share consumer health data with business partners only:

• With your affirmative express consent
• For purposes you specifically authorized
• In compliance with all notice and consent requirements

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