Effective March 28th, 2024
SPD Swiss Precision Diagnostics GmbH and SPD Development Company Limited ( hereinafter “SPD”, “We”) are committed to respecting your privacy. Our Global Privacy Policy describes how we handle your personal data generally. This supplemental Consumer Health Data Privacy Policy (“Health Privacy Policy”) explains our practices for “Consumer Health Data” as such term is defined by applicable laws including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. Health Privacy Laws”).
“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as biometric data, information about use of non-prescription medication or use of health-related products., for example. Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship.
If we make any material updates to this Health Privacy Policy, we will notify you as required by U.S. Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Policy earlier than required. We reserve the right to amend this Health Privacy Policy at our discretion and at any time.
Categories of Consumer Health Data that We Collect
SPD only collects, uses and discloses Consumer Health Data as needed to provide you with the products or services that you request or with your consent.
SPD may collect Consumer Health Data related to the following categories of Consumer Health Data:
- Product Interests. Information about your interest in health-related brands or products, such as when you visit some of our websites and mobile applications or buy certain products.
- Individual Health Conditions, Treatments and Diseases. Information about your health history, symptoms and/or treatment, such as pregnancy status.
- Bodily Function, Vital Signs and Measurements. Information about the operations of the systems of your body, such as digestion, metabolism, immune support or height and weight.
- Reproductive and Sexual Health Information. Information about your reproductive system or sexual well-being collected when you voluntarily provide it to certain websites or mobile applications or buy certain products, such as information about your periods or pregnancy status.
- Research Programs. Information you provide when participating in research studies or responding to our surveys including any of the above categories about physical or mental health, medical history or other health-related information.
Purposes for Collecting Consumer Health Data and How We Use It
We may use your Consumer Health Data for the following Processing Purposes:
- Products/Services, including performing services for you and sending you certain products or samples you have requested.
- Consumer Management, such as:
- Identifying and authenticating you to our different marketing programs, websites, and mobile apps.
- Administering and maintaining accounts and preferences, as well as financial incentive, rewards, discounts (e.g., price or service coupons) and loyalty programs.
- Helping you manage your website or app preferences.
- Allowing you to enter our contests or sweepstakes and leaving ratings and reviews for products.
- Consumer Service/Communications, such as:
- Responding to your questions or requests for information
- Sending transactional messages (such as account statements or confirmations).
- Sending marketing communications about our products or services (or the products or services of our partners), surveys, and invitations.
- Payment/Financial, such as processing your financial details for managing refunds.
- Serving Ads, including serving you with relevant ads about our brands and programs.
- Ads Administration, such as measuring and tracking the effectiveness of advertising campaigns and carrying out other administrative and accounting activities with respect to ad campaigns.
- Quality and Safety, including:
- Quality control, training, and analytics.
- Safety maintenance and verification.
- System administration and technology management, including optimizing our websites and applications.
- Security, including detecting threats and protecting against malicious or fraudulent activity.
- Recordkeeping and Auditing, including recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information.
- Legal/Compliance, including risk management, audit, investigations, reporting and other legal and compliance reasons.
- Research & Development (“R&D”), such as
- Internal research,
- Clinical study applications,
- Designing and developing new products, services, and programs.
Sources of Consumer Health Data
We collect Consumer Health Data from the following sources:
- From you, such as when you request certain health-related products and services, join certain brand marketing email lists or loyalty programs, or volunteer the information in connection with surveys or promotions.
- From your interactions with us, such as when you use our health-related apps or browse our websites for brands related to health.
- From our business and marketing partners, who provide us with information about consumers who are viewing our content across websites or apps, purchasing our products, or taking advantage of our promotions.
- From other third-party sources such as data brokers who provide us with information about consumers that may be interested in our products.
- We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.
Disclosures of Consumer Health Data
We do not sell your Consumer Health Data. We also do not share your Consumer Health Data with any Third Parties or Affiliates.
We may disclose the categories of Consumer Health Data described above in the following circumstances:
- We may disclose Consumer Health Data with our data processors, service providers and contractors who assist us in providing goods and services to you. These processors may only use the data as permitted by our contracts with them.
- We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or a transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.
Your Privacy Rights
You have specific rights with respect to your Consumer Health Data:
- You have the right to know if we are collecting, using or disclosing your Consumer Health Data, to access that consumer health data, including receiving a list of the entities and affiliates with whom we have shared or sold your information, though currently we do not sell or share your Consumer Health Data with Third Parties or Affiliates.
- You have the right to request that we delete your Consumer Health Data.
- If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. For cookie-related Consumer Health Data, you can do this by visiting your “Cookie consent” at the bottom of our health-related websites or in the Settings menu of our mobile applications. Withdrawing your consent for collection of non-cookie related Consumer Health Data will effectuate a deletion request.
We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services.
To exercise these rights, please contact us. We will authenticate your requests and process it as required by law. Please allow up to 45 days for a response. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:
- Washington State Attorney General at www.atg.wa.gov/file-complaint.
- Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
Please contact us directly with any questions or concerns you may have about your Consumer Health Data privacy or this Health Privacy Policy.