Joon Care Washington Consumer Health Data Privacy Policy

This Washington Consumer Health Data Privacy Policy supplements the information in Joon Care’s Privacy Policy. This Washington Consumer Health Data Privacy Policy only applies to personal information of Washington residents that we process and that is “consumer health data” subject to the Washington My Health My Data Act (“MHMDA”).

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Any terms in this Washington Consumer Health Data Privacy Policy that are defined in MHMDA will have the same meaning as in that law, to the extent the law applies. The term “Services” referenced in this policy refers to the Joon websites, mobile applications, our teletherapy services for teens and young adults and any of our other online or offline offerings that link to this Washington Consumer Health Data Privacy Policy.

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CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT

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Under the MHMDA, “consumer health data” is defined as “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.”

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Because consumer health data is defined very broadly, many of the categories of personal information that we collect under our Privacy Policy may also be considered consumer health data.

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Examples of consumer health data that you may provide to us, or that we may otherwise collect, may include:

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• Information that could identify your attempt to seek health care services or information from us, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, we collect your search queries on the Joon Services, which may include queries or other information concerning nutrition, wellness, fitness, medical conditions, mental health, or other health-related topics.
• Information about your health-related conditions, symptoms, status, diagnoses, disease, testing, or treatments.
• Information about social, psychological, behavioral, and medical interventions. 
• Information about use or purchase of prescribed medication. 
• Information about measurements of bodily functions, vital signs, or symptoms.
• Information about diagnostic testing, treatment, or medication.
• Information about surgeries or other health-related procedures.  
• Reproductive or sexual health information. 
• Information about gender-affirming care. 
• Biometric information. 
• Genetic data. 
• Information related to the precise (geo)location information of a consumer that could reasonably indicate an attempt by a consumer to receive health services or supplies.
• Other information that may be used to infer or derive data related to the above or other consumer health data. 

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SOURCES OF CONSUMER HEALTH DATA

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We collect consumer health data that you provide to us, consumer health data we collect automatically when you use the Services, and consumer health data from third-party sources, as described in our Privacy Policy and below. Additionally, we may collect Consumer Health Data as follows: 

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• Directly from you, if you:
  
  • request health-related products and services from Joon;
  • fill out our lead registration form; 
  • register to use Joon mobile application; or
  • join our email lists.

• Indirectly from you if you:
  
  • interact with us by using our app or accessing our website;
  • enable certain mobile app functions, such as location tracking;
  • make your health data publicly available on social media or other websites; or
  • like, follow, or comment about health-related products on our social media sites.

• From our vendors, suppliers, consultants, Treatment Providers, and other third parties, when:
  
  • Contact information, payment information, and other data is necessary for the purpose of managing and operating our business.

• From third parties who provide therapy enrollment, benefit verification, or product fulfillment services.

• Health Insurance Companies or other payors, when:
  
  • Information is necessary for the purpose of providing our products and services;
  • Information is necessary to determine therapy eligibility; or
  • Information is necessary to comply with legal and regulatory obligations.

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• Your authorized legal representative, family members, or caregivers.

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WHY WE COLLECT AND HOW WE USE CONSUMER HEALTH DATA

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We collect and use consumer health data for the purposes and in the manner described in the “How We Use Personal Information” section of the Privacy Policy. 

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Primarily, we collect and use consumer health data as reasonably necessary to provide you with our Services you have requested. This may include:

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• Determining and verifying program, product, and service eligibility and coverage;
• Enrolling you in our programs and providing our services to you;
• Administering, managing, analyzing, troubleshooting, and improving our programs and Services;
• Procuring vendor or supplier products and services, including to manage and satisfy related vendor or supplier contractual obligations;
• Analyzing and better understanding your needs, preferences, and interests, as well as those of other consumers;
• Conducting internal business analysis and market research;
• Ensuring the secure and reliable operation of the Services and the systems that support them;
• Monitoring, investigating, and enforcing compliance with our policies, service terms and conditions, and legal and regulatory requirements;
• Complying with legal and regulatory obligations; or
• For our other essential business operations that support the provision of the Services.

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We may also collect consumer health data for other purposes for which we will obtain your consent as required by law.

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CATEGORIES OF CONSUMER HEALTH DATA WE SHARE 

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We may share each of the categories of consumer health data described above for the purposes described above and in the “How We Use Personal Information” section of the Privacy Policy. In particular, we may share consumer health data with your prior consent or as reasonably necessary to complete any transaction or provide any product or Service you have requested, as described above.

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THIRD PARTIES WITH WHICH WE SHARE CONSUMER HEALTH DATA

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We may share consumer health data with the categories of third parties listed in the “How We Disclose Personal Information” section of the Privacy Policy. 

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HOW TO EXERCISE YOUR RIGHTS

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MHMDA provides consumers with certain rights with respect to consumer health data. 

Under MHMDA, consumers have the right to: 

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• confirm whether Joon Care is collecting, sharing, or selling consumer health data and to access such data; 
• withdraw consent from Joon Care’s collection and sharing of consumer health data; or  
• request that Joon Care delete consumer health data.

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You can request to exercise such rights by contacting us at privacy@joon.com.

If your request to exercise a right under MHMDA is denied, you may appeal that decision by contacting us at privacy@joon.com. 

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If your appeal is unsuccessful and your consumer health data is subject to MHMDA, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

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UPDATES TO THIS WASHINGTON CONSUMER HEALTH DATA PRIVACY POLICY

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We may update this Washington Consumer Health Data Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Washington Consumer Health Data Privacy Policy on our website, or by sending you other communications.

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