Consumer Health Data Privacy Policy

This policy describes how Upheld Health Technologies collects, uses and shares consumer health data, as those terms are defined by the Washington My Health My Data Act. It applies to consumers who are Washington residents and to consumers whose consumer health data is collected in Washington. It is maintained separately from our general Privacy Policy.

Categories of consumer health data we collect

• Information a caregiver chooses to record with Goldie about the health of the person they care for, including medications and doses, symptoms and events, appointments and care-team instructions.
• The timing of those entries, such as when a medication was given or an event was logged.
• Information about a caregiver’s own health, if they choose to record it.
• Health status that could reasonably be inferred from the above.

Sources of that data

Directly from the consumer, through messages they send to Goldie. We do not purchase consumer health data and do not obtain it from data brokers.

Purposes for collecting and using it

• To deliver the reminders and messages the consumer has asked for.
• To answer the consumer’s questions about information they previously recorded.
• To operate, secure and maintain the service.
• To comply with legal obligations.

Categories of consumer health data we share

We share the categories described above only with the processors listed below, and only to operate the service. We do not share consumer health data for advertising or marketing.

Categories of third parties and affiliates we share with

• Message delivery providers, to send and receive text messages.
• Cloud infrastructure and hosting providers, to store and process data.
• Recipients required by law, where we are legally compelled to disclose.

These parties act as our processors under contract and may use the data only to perform services for us.

We do not sell consumer health data

We do not sell consumer health data, and we will not do so without first obtaining valid written authorization from the consumer as required by the Act.

Your rights

If you are a Washington consumer, you have the right to:

• Confirm whether we are collecting, sharing or selling your consumer health data, and access that data.
• Obtain a list of all third parties and affiliates with whom we have shared or to whom we have sold your consumer health data, and contact information for each.
• Withdraw your consent to our collection and sharing of your consumer health data.
• Have your consumer health data deleted.

How to exercise these rights

Email katelyn@upheldhealth.org with your request. We will verify your request by confirming control of the phone number or email address associated with the data, and will respond within 45 days, or tell you if we need a 45-day extension.

If we decline your request, you may appeal by replying to our decision. We will respond to an appeal within 45 days. If we deny the appeal, you may contact the Washington State Attorney General at atg.wa.gov/file-complaint.

Changes

We will not collect, use or share consumer health data for purposes beyond those described here without first obtaining affirmative consent.