HealthCentral™ Consumer Health Data Privacy Notice

Last updated: June 24, 2026

HealthCentral is committed to protecting your privacy and, for that reason, we have adopted this Consumer Health Data Privacy Notice (the “Notice”) to explain our Consumer Health Data (as defined below) collection, use, and disclosure practices for the HealthCentral services (including the Drops mobile and web-based apps (“Drops”) and any other tools, products, or services provided by HealthCentral that link to or reference this Notice) (collectively with Drops, the “Services”). The Services are owned and operated by HealthCentral LLC, a Delaware limited liability company (“HealthCentral”, “we”, “us” or “our”). This Notice supplements the information contained in our Privacy Policy and applies only if you reside in the States of Nevada or Washington or your Consumer Health Data (as defined below) was collected in Washington State (you are a “Health Data Covered Consumer”).

By accessing or using the Services, including without limitation Drops, you consent to (i) our collection of the categories of Consumer Health Information, (ii) the purposes for which we will collect and share Consumer Health Information, (iii) the categories of Consumer Health Information that we will share, and (iv) the categories of entities with whom we will share Consumer Health Information, each as set forth in this Notice. If you do not agree with the Consumer Health Information collection, processing, and sharing set forth in this Notice, please do not access or use the Services, including without limitation Drops.

The Nevada Consumer Health Data Privacy law (“SB370”) and the Washington My Health, My Data Act (the “MHMDA”, collectively with SB370, the “Consumer Health Data Privacy Laws”) define Consumer Health Data very broadly, and includes information you may not typically think of as health data. For the purposes of this Notice, “Consumer Health Data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status, including (i) Individual health conditions, treatment, diseases, or diagnosis; (ii) social, psychological, behavioral, and medical interventions; (iii) health-related surgeries or procedures; (iv) use or purchase of prescribed medication; (v) bodily functions, vital signs, symptoms, or measurements of other information that is Consumer Health Data; (vi) diagnoses or diagnostic testing, treatment, or medication; (vii) gender-affirming care information; (viii) reproductive or sexual health information; (ix) biometric data; (x) genetic data; (xi) precise location information that could reasonably indicate a consumer's attempt to acquire or receive health services or supplies; (xii) data that identifies a consumer seeking health care services; or (xiii) any information that we process to associate or identify a Health Data Covered Consumer with the data described in (i) through (xii) that is derived or extrapolated from non-health information.

“Sell” or “sale” means the exchange of Consumer Health Data for monetary or other valuable consideration. “Sell” or “sale” does not include the exchange of Consumer Health Data for monetary or other valuable consideration: (i) to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of HealthCentral’s assets; or (ii) by HealthCentral to a third party when such exchange is consistent with the purpose for which the Consumer Health Data was collected and disclosed to the consumer.

Collection of your Consumer Health Data

When you use Drops, we may collect the following types of Consumer Health Data from you:

Information related to individual health conditions, treatment, diseases, or diagnosis;
Information related to use or purchase of prescribed medication;
Information related to social, psychological, behavioral, and medical interventions;
Information related to diagnoses or diagnostic testing, treatment, or medication;
Information related to gender-affirming care;
Information related to reproductive or sexual health information;
Information that identifies you as seeking health care services;
Any other type of Consumer Health Data you choose to share in via Drops; and
Any inferences of Consumer Health Data derived, extrapolated, or inferred from non-health information.

Sources of Consumer Health Data

HealthCentral obtains Consumer Health Data from the following types of sources:

Directly from you, for example, when you use Drops to discuss your issues that involve Consumer Health Data.
Indirectly from you, for example, when we automatically collect non-health information from you based on your interaction with the Services and make inferences from non-health information that would be considered Consumer Health Data.

Use of Consumer Health Data

We only collect and use Consumer Health Data as is reasonably necessary to provide Drops functionality you have chosen to use, requested or authorized. We collect and use Consumer Health Data for the following purposes:

To assist us in providing, maintaining, and protecting the Services;
To perform research and analysis aimed at improving our products and services and developing new products or services;
Set up, maintain, and protect accounts to use Drops;
Improve our online operations;
Process transactions;
Provide customer service;
Communicate with you, such as provide you with account- or transaction-related communications, or other communications relating to the Services;
Prevent fraud and other misuse;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
To respond to your requests under the Consumer Health Data Privacy Laws;
For any other purpose described to you and to which you consent when we collect your Consumer Health Data; and
For any other acceptable purposes as set forth in the Consumer Health Data Privacy Laws.

Disclosure of Consumer Health Data

We may disclose the following categories of Consumer Health Data:

Information related to individual health conditions, treatment, diseases, or diagnosis;
Information related to use or purchase of prescribed medication;
Information related to social, psychological, behavioral, and medical interventions;
Information related to diagnoses or diagnostic testing, treatment, or medication;
Information related to gender-affirming care;
Information related to reproductive or sexual health information;
Information that identifies you as seeking health care services;
Any other type of Consumer Health Data you choose to share in via Drops; and
Any inferences of Consumer Health Data derived, extrapolated, or inferred from non-health information.

We may disclose the Consumer Health Data we collect to processors, service providers, and contractors that help us provide Drops. When we disclose Consumer Health Data to a processor, service provider, or contractor, we enter into an agreement with the receiving party that describes the purpose for disclosing the Consumer Health Data, and that requires the receiving party to keep that Consumer Health Data confidential.

We may also disclose consumer health data as permitted by applicable law, including:

With your consent;
To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities;
To a third party acquiring our assets if HealthCentral sells its business or otherwise is part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control of our assets or business;
To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others;
To protect your or others' vital interests, including health and safety;
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations
To respond to your requests under the Consumer Health Data Privacy Laws;
For any other purpose described to you when we collect your Consumer Health Data; and
For any other acceptable purposes as set forth in the Consumer Health Data Privacy Laws.

HealthCentral does not, and will not, without first obtaining your consent, Sell your Consumer Health Data.

Your Consumer Health Data Rights and Choices

If you are a Health Data Covered Consumer, you may exercise the rights described below by submitting a request to HealthCentral by email at privacy@healthcentral.com. Please be sure to include your name and phone number in your request, so that we can match it with the information we maintain about you, in order to assist us in verifying your identity. If we are unable to verify your identity, we will not be able to process your request. We reserve the right to request additional information from you in order to ensure that we are able to verify your identity when you make a request.

You may request information about our collection and processing of your Consumer Health Data, whether or not it was collected electronically. If you submit a request, we will disclose whether we have collected or processed your Consumer Health Data and allow you to access the Personal Information we have collected, including a list of all third parties with whom we have shared your Consumer Health Data, to the extent we continue to retain the Consumer Health Data. In the event that you make more than two (2) requests in any twelve (12) month period, we reserve the right to charge a fee prior to processing any such request(s).

You also have the right to request that we delete any of your Consumer Health Data that we collect or maintain. If the Consumer Health Data that you request we delete is stored on archived or backup systems, then your request for deletion may be delayed for up to six months to enable restoration of the archived or backup systems.

After we receive your request and verify your identity, we will provide to you, in writing, the requested information. You can choose to have this information delivered to you by postal mail or electronically. For any request, except for a request to delete your Consumer Health Information, we will try to respond to your verified request within forty-five (45) days of receipt, but if we require more time (up to another forty-five (45) days) we will inform you of the reason and extension period in writing. For any request to delete your Consumer Health Information, we will respond to your verified request within thirty (30) days of receipt. If we decline to act on your request for any reason permitted under the Consumer Health Data Privacy Laws, we will notify you of our decision within forty-five (45) days of receiving your request (except for requests to delete you Consumer Health Information, which we will respond to within thirty (30) days of receiving your request). If applicable, our response will explain the reasons why we cannot comply with your request.

If we deny your request or fail to act on it within the required time period, you may have the right to appeal this decision by submitting a new request in which you conspicuously note that you are appealing a previous decision. We will respond to your verified request to appeal within forty-five (45) days. If applicable, our response will explain the reasons why we are denying your appeal, and any further steps that may be available to you.

You also have the right to withdraw your consent for our collection, processing, or sharing of your Consumer Health Information at any time by emailing us at privacy@healthcentral.com. However, please be advised that if you withdraw your consent for our collection, processing, and/or sharing of your Consumer Health Information, you will no longer be able to continue using Drops.

Updates to this Notice

We reserve the right, at our discretion, to change the terms of this Notice from time to time. You can see when this Notice was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to this Notice as appropriate under the circumstances via our website or other means of contact. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS NOTICE WILL APPLY IMMEDIATELY UPON POSTING TO THE SERVICES. If you use the Services after we have published such changes, you will be agreeing to be bound by those changes.

Questions

To ask questions about our Consumer Health Data Privacy Notice or to lodge a complaint, contact us at:

HealthCentral LLC

Email: privacy@healthcentral.com