Hone Health Privacy Policy Addendum for Washington Residents

Effective Date: August 1, 2025

This Washington Consumer Health Data Privacy Policy supplements the Hone Health Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (“MHMDA”). This Washington Consumer Health Data Privacy Policy only applies to individual consumers who are residents of the state of Washington or individuals whose consumer health data is collected in the state of Washington.In the event of a conflict between any other policy, statement, or notice and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy will control as to Consumer health data collected under WA MHMDA.

“Consumer health data” means personal information that is linked or reasonably linkable to a particular individual and that identifies that individual’s past, present, or future physical or mental health status. However, the following categories of information are not consumer health data and not covered by this Washington Consumer Health Data Privacy Policy:

• Protected Health Information (“PHI”), as defined by the Health Insurance Portability and Accountability Act (“HIPAA”);
• Health care information collected, used, or disclosed in accordance with WA Revised Code § 70.02 (“Medical Records – Health Care Information Access and Disclosure”);
• Publicly available information;
• Deidentified data; or
• Information otherwise excluded from the scope of Washington MHMDA.

Please note that data practices concerning Protected Health Information collected by independent medical practitioners (“Medical Group”), an independent medical group with a network of United States-based health care providers (each, a “Provider”) and its affiliates are described in the terms and privacy disclosures specific to those services, namely, the Provider’s Notice of Privacy Practices.

Categories of Consumer Health Data We Collect

As described in the Privacy Policy, the data we collect depends on the context of your interactions with Hone Health and the choices you make (including your privacy settings), the products and features you use, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data. 

We may collect the following categories of consumer health data with your consent or to the extent necessary to provide a product or service that you requested. We only collect the categories of consumer health data described in this Washington Consumer Health Data Privacy Policy.

• 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 other health data;
• Diagnoses or diagnostic testing, treatment, or medication;
• Reproductive or sexual health information;
• Biometric data;
• Precise location information that could reasonably indicate an individual’s attempt to acquire or receive health services or supplies;
• Data that identifies a consumer seeking health care services; and
• Any other information used to associate or identify an individual with any category of health data that is derived or extrapolated from non-health information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning)

Examples of consumer health data may include:

• Health information you choose to provide via our “Treat Me Now” form.
• Other information that may be used to infer or derive data related to the above or other health information.

Sources of Consumer Health Data

As described further in our Privacy Policy, we collect personal data (which may include consumer health data) directly from you and from your interactions with our products and services, including from inferences from your activity using our services. We may also collect personal data (which may include consumer health data) from our business partners and service providers and from publicly available sources.

Purposes for Collecting and Using Consumer Health Data 

We only collect and use consumer health data for the purposes described in this Washington Consumer Health Data Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to communicate with you and to provide you with the products and services you have requested. We may also collect and use consumer health data for the following purposes: 

• Operate, maintain, supervise, administer, and enhance our Platform or the Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Services such as assisting you in completing the registration process.
• Provide our Products and Services to you, in a custom and user-friendly way.
• Provide you with information, Products, or Services that you request from us or that may be of interest to you.
• Promote and market our Platform and/or the Services to you. For example, we may use your Personal Information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Products or information we think may interest you. We also may use the Personal Information that we learn about you to assist us in advertising our Services on third party websites. You can opt-out of receiving these e-mails at any time as described below.
• Provide you notices about your account.
• Contact you in response to a request.
• Notify you about changes to our Platform and/or the Services or any Products we offer or provide through them.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Anonymize and aggregate Personal Information for analytics and reporting.
• Respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
• Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
• Administer surveys and questionnaires.
• Provide you information about goods and services that may be of interest to you, including through newsletters.
• Any other purpose with your consent.

Sharing of Consumer Health Data

We may share consumer health data with your consent or as reasonably necessary to provide a product or service that you have requested. “Share” under the Washington MHMDA means to release, disclose, disseminate, divulge, make available, provide access to, license, or otherwise communicate consumer health data to a third party or affiliate. However, “share” does not include (i) disclosure of consumer health data to provide goods or services in a manner consistent with the purpose for which we collected the consumer health data; (ii) disclosure to a third party with whom you have a direct relationship when the disclosure is for the purpose of providing a product or service you, if we maintain control and ownership of the data, and the third party uses the data only at our direction and consistent with your consent and for the purpose for which it was collected; or (iii) disclosure or transfer of consumer health data to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in compliance with the Washington MHMDA. The term “third party,” as used in this Washington Consumer Health Data Privacy Policy, means a person who is not a consumer, an entity regulated under the Washington MHMDA, a processor, or an affiliate of an entity regulated under the Washington MHMDA.

We may share consumer health data to the following categories of third parties and specific affiliates:

• business partners or service providers, such as those providing analytics and technology services; 
• affiliates, parents, and subsidiary organizations of Hone Health; advertisers and advertising networks; 
• potential or actual buyer or other successor in interest; and 
• other third parties (such as law enforcement or government regulators) where required by, or otherwise permitted by, law

How to Exercise Your Rights

If you are covered by the Washington MHMDA, then you have certain rights with respect to consumer health data, including: 

• The right to confirm whether we are collecting, sharing, or selling your consumer health data;
• The right to access a copy of the consumer health data we have about you;
• The right to delete your consumer health data;
• The right to withdraw consent for the collection and/or sharing of your consumer health data, subject to certain exceptions;
• The right to appeal our decisions on requests to exercise any of these rights.

You can request to exercise such rights by contacting our privacy support team at support@honehealth.com (with the subject line “Health Privacy Rights Request”). You may submit a rights request, free of charge, up to two times per year. We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. 

If your request to exercise a right is denied, you may appeal that decision by contacting our privacy support team at support@honehealth.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Sales of Consumer Health Data

The WA MHMDA defines a “sale” as the exchange of consumer health data for monetary or other valuable consideration, excluding exchange (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 our assets that complies with the requirements and obligations in the WA MHMDA; or (ii) by us to a processor when such exchange is consistent with the purpose for which the consumer health data was collected and disclosed to the consumer. As required by law, we only sell consumer health data after we have obtained a valid authorization from the consumer whose consumer health data is involved in the sale. If you have previously authorized us to sell your consumer health data, you can revoke that authorization at any time by contacting us at support@honehealth.com for information on how to revoke your authorization.

Changes to this Washington Consumer Health Data Privacy Policy

We reserve the right to amend this Washington Consumer Health Data Privacy Policy at our discretion and at any time. When we make material changes to this Washington Consumer Health Data Privacy Policy, we will post the updated version on our website and update the Last Updated date. Your continued use of our website and services following the posting of changes constitutes your acceptance of such changes.

Contact Us

If you have any questions, concerns, complaints or suggestions regarding this Washington Consumer Health Data Privacy Policy or otherwise need to contact us, 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. 14^th St., 3-121
New York, NY 10011