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Hone Health Privacy Policy Addendum for California Residents

Effective Date: November 21, 2024

Last Reviewed on: November 21, 2024

1. Introduction

This CPRA Privacy Addendum supplements the information in our Privacy Policy for residents of California.

This Privacy Policy Addendum for California Residents (the “California Privacy Addendum”) supplements the information contained in Hone Health’s Privacy Policy and describes our collection and use of Personal Information (as defined below). This California Privacy Addendum applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”) and any terms defined in the CPRA have the same meaning when used in this notice.

2. Scope of this California Privacy Addendum

This California Privacy Addendum applies to Personal Information that we collect on our Website when you use our products and services. However, it does not apply to any Personal Information we may collect if you are an employee, job applicant, contractor, or have a similar relationship with Hone Health or if you have a business-to-business relationship with us.   

This California Privacy Addendum applies to information that we collect on our Website when you use our products and services (both online and offline) and that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“Personal Information”). However, publicly available information that we collect from government records and deidentified or aggregated information (when deidentified or aggregated as described in the CPRA) are not considered Personal Information and this California Privacy Addendum does not apply to such information.

This California Privacy Addendum does not apply to employment-related Personal Information collected from our California-based employees, job applicants, contractors, or similar individuals (“Personnel”). Please contact your local human resources department if you are part of our California Personnel and would like additional information about how we process your Personal Information.

This California Privacy Addendum also does not apply to certain Personal Information that is excluded from the scope of the CPRA, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

3. Information We Collect About You and How We Collect It

The Personal Information we collect, and have collected over the past 12 months, includes the following categories of Personal Information: Identifiers; certain information protected under the California Records Statute; information related to protected classes under California or federal law; internet and network information; geolocation data; and professional/employment related information.We may also collect, and may have collected over the past 12 months, the following categories of Sensitive Personal Information: government identifiers; complete account access credentials; racial or ethnic origin; and health, sex life, or sexual orientation information.

Hone Health collects, and over the prior twelve (12) months has collected, the following categories of Personal Information about Consumers:

Personal Information CategoryApplicable Pieces of Personal Information Collected
Identifiers.A real name; postal address; online identifier; Internet Protocol address; email address; Social Security number; and other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name; Social Security number; physical characteristics or description; address; telephone number; employment; employment history; credit card number; medical information; and health insurance information.Some Personal Information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law.Age (40 years or older); race; marital status; medical condition; physical or mental disability; sex (including gender, gender identity, gender expression, and sexual orientation).
Internet or other similar network activity.Browsing history; search history; information on a Consumer’s interaction with a website, application, or advertisement.
Geolocation data.Physical location or movements. We collect IP-based information about your physical location or movements. This IP-based information can only identify your physical location or movements to a geographic region, such as town, city, state, and country, but cannot be used to identify your precise physical location or movements.
Professional or employment-related information.Current or past job history or performance evaluations.
Sensitive Personal Information (“Sensitive Personal Information”)·  Government identifiers (Social Security; driver’s license; state identification card; or passport number)·  Racial or ethnic origin·  Health; sex life; or sexual orientation information.

Hone Health will not collect additional categories of Personal Information without providing you notice.

4. Sources of Personal Information

We collect Personal Information about you from the sources described in our Privacy Policy.

As described in our Privacy Policy, we collect your Personal Information: directly from you, automatically from your use of our Website, and from third parties, such as third-party laboratories when we receive test results. We may also create Personal Information about you as you use our Website.

5. Purposes for Our Collection of Your Personal Information

We only use your Personal Information for the purposes described in our Privacy Policy.

We may use, “sell” for monetary or other valuable consideration, “share” for the purposes of cross-context behavioral advertising, or disclose the Personal Information we collect and, over the prior twelve (12) months, have used, “sold” for monetary or other valuable consideration, shared for the purpose of cross-context behavioral advertising, or disclosed the Personal Information we have collected, for the purposes described in our Privacy Policy as well as the following additional purposes:

Hone Health will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

6. Third Parties to Whom Do We Disclose Your Personal Information for Business Purposes

We may disclose your Personal Information to certain categories of third parties for various business purposes.

Hone Health may disclose your Personal Information to third parties for one or more business purposes. When we disclose Personal Information to non-affiliated third-parties for a business purpose, we enter a contract that describes the purpose, requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the specific business purposes for which the Personal Information was disclosed, and requires the recipient to otherwise comply with the requirements of the CPRA. The CPRA prohibits third parties who purchase the Personal Information we collect from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

In the preceding twelve (12) months, Hone Health has disclosed the following categories of Personal Information for one or more of the business purposes described below to the following categories of third parties:

Personal Information CategoryCategories of Third Party Recipients
Identifiers.Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Protected classification characteristics under California or federal law.Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Internet or other similar network activity.Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Geolocation data.Service Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Sensitive Personal Information CategoryCategories of Third Party Recipients
Government identifiers (Social Security, driver’s license, state identification card, or passport number)Service Providers; business partners; affiliates, parents, and subsidiary organizations of Hone Health; or potential or actual buyer or other successor in interest.
Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password)Service Providers; business partners; affiliates, parents, and subsidiary organizations of Hone Health; or potential or actual buyer or other successor in interest.
Racial or ethnic originService Providers; business partners; affiliates, parents, and subsidiary organizations of Hone Health; or potential or actual buyer or other successor in interest.
Health, sex life, or sexual orientation informationService Providers; business partners; affiliates, parents, and subsidiary organizations of Hone Health; or potential or actual buyer or other successor in interest.

We disclose your Personal Information to the categories of third parties listed above for the following business or commercial purposes:

In addition to the above, we may disclose any or all categories of Personal Information to any third-party (including government entities and/or law enforcement entities) as necessary to:

7. To Whom Do We Sell or Share Your Personal Information

We do not disclose your Personal Information to third parties for monetary consideration. However, our use of advertising and analytics cookies may be considered a disclosure of Personal Information for other valuable consideration.We may also disclose your Personal Information to certain categories of third parties for the purpose of cross-context behavioral advertising.

“Sale” of Your Personal Information for Monetary or Other Valuable Consideration

As noted in our Privacy Policy, we do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. However, the use of advertising and analytics cookies on our Website is considered a “sale” of Personal Information as the term “sale” is broadly defined in the CPRA to include both monetary and other valuable consideration. Using this broad definition, our “sale” is limited to our use of third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Website(s). Our “sales” of your Personal Information in this manner is subject to your right to opt-out of those sales (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information). The CPRA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

“Sharing” of Your Personal Information for Cross-Context Behavioral Advertising

Hone Health may “share” your Personal Information for the purpose of cross-context behavioral advertising, subject to your right to opt-out of that sharing (see Your Choices Regarding our “Sale” or “Sharing” of your Personal Information). Our “sharing” for the purpose of cross-context behavioral advertising would be limited to our use of third-party advertising cookies and their use in providing you cross-context behavioral advertising (i.e., advertising on other websites or in other mediums). When the recipients of your Personal Information disclosed for the purpose of cross-context behavioral advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure as a “sale” for monetary or other valuable consideration under the CPRA.

In the preceding twelve (12) months, Hone Health has “sold” for monetary or other valuable consideration, or “shared” for the purpose of cross-context behavioral advertising, the following categories of Personal Information to the following categories of third parties:

Personal Information CategorySold or SharedCategories of Third Parties To Whom Your Personal Information is Sold or Shared
Identifiers.SharedService Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).SharedService Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Protected classification characteristics under California or federal law.SharedService Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Internet or other similar network activity.SharedService Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.
Geolocation data.SharedService Providers; advertisers and advertising networks; business partners; affiliates, parents, and subsidiary organizations of Hone Health; social media companies; Internet cookie information recipients, such as analytics and behavioral advertising services; or potential or actual buyer or other successor in interest.

Sale or Sharing of Personal Information of Minors Under the Age of 16

We do not have any actual knowledge that we “sell” the Personal Information of minors under the age of 16 for monetary or other valuable consideration and we do not have any actual knowledge that we “share” such Personal Information for cross-context behavioral advertising without affirmative consent as required by the CPRA. More information on how minors under the age of 16 may change their choice regarding the “sale” or “sharing” of their Personal Information can be found in Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

8. Consumer Data Requests

You have certain rights with respect to your Personal Information under the CPRA, including the right to access your Personal Information and have it deleted (each under certain limitations).

The CPRA provides California residents with specific rights regarding their Personal Information. This section describes your CPRA rights and explains how to exercise those rights. You may exercise these rights yourself or through your Authorized Agent. For more information on how you or your Authorized Agent can exercise your rights, please see Exercising Your CPRA Privacy Rights.

Exercising Your CPRA Privacy Rights

To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:

If you fail to make your Consumer Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request.

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see Authorized Agents below.

All Consumer Requests must:

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you or the individual for whom you are making the request as their Authorized Agent.

Making a Consumer Request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information.

Authorized Agents

You may authorize your agent to exercise your rights under the CPRA on your behalf by providing them with written authorization or with power of attorney to exercise your rights in accordance with applicable laws (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.

9. Your Choices Regarding our “Sale” or “Sharing” of Your Personal Information

If you are 16 years old or older, you have the right to opt-out of our sale and/or sharing of your Personal Information.  If you are under 16 years old, you or your legal guardian may opt-in to our sale or sharing of your Personal Information.

“Sale” of Your Personal Information

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information for monetary or other valuable consideration at any time (the “right to opt-out”). We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

“Sharing” of Your Personal Information

If you are 16 years of age or older, you have the right to direct us to not share your Personal Information for the purposes of cross-context behavioral advertising, which is showing advertising on other websites or other media based on your browsing history with our Website (the “right to opt-out”). We do not share the Personal Information of Consumers we actually know are less than 16 years of age for this purpose, unless we receive affirmative authorization from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to our sharing of Personal Information for these purposes may opt-out of future such sharing at any time.

How You May Opt-Out of Our Sale or Sharing of Your Personal Information

To exercise your right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and of “sharing” your Personal Information for the purposes of cross-context behavioral advertising, you (or your Authorized Agent) may use any of the following methods:

Your Privacy Choices

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize our “sale” and “sharing” of your Personal Information. However, you may change your mind and opt back into the “sale” and “sharing” of Personal Information at any time by adjusting your cookie preferences on our site or modifying your browser’s cookie settings.

Browser Privacy Control Signals

You may also exercise your right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration and “sharing” your Personal Information for the purposes of cross-context behavioral advertising by setting the privacy control signal on your browser, if your browser supports it. We currently recognize and support the following privacy signals sent by browsers:

When we receive a privacy control signal, we will opt you out of any further “sale” or “sharing” of your Personal Information when you interact with our Website through that browser and on that device.

10. Your Choices Regarding our Use and Disclosure of Your Sensitive Personal Information

As further described below, we  do not use and/or disclose your Sensitive Personal Information for purposes other than the use and disclosure necessary to provide you with the products and services expected of an average Consumer.

As further described below, we do not use or disclose your Sensitive Personal Information for any purpose other than the following:

In addition, we may also use or disclose your Sensitive Personal Information for the following purposes:

Because we only use your Sensitive Personal Information for the purpose above as enumerated or otherwise permitted under the CPRA, we are not required to, and do not, provide you with any right to limit the use and disclosure of your Sensitive Personal Information for only the above uses and disclosures.

11. Changes to This California Privacy Addendum

We will post any changes to our California Privacy Addendum on our Website. If we make material changes to this California Privacy Addendum, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

Hone Health reserves the right to amend this California Privacy Addendum at our discretion and at any time. When we make changes to this California Privacy Addendum, we will post the updated addendum on the Website and update the addendum’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

12. Contact Information

If you have any questions or comments about this California Privacy Addendum or the ways in which we collect and use your Personal Information, or wish to exercise your rights under California law, please contact us at the contact information below.

If you have any questions or comments about this California Privacy Addendum, the ways in which Hone Health collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (833)-444-4483

Website: www.honehealth.com

Email: support@honehealth.com

Postal Address:
Hone Health
Attn: Legal
154 W. 14th St., 3-121
New York, NY 10011