Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy (Notice) provides additional information regarding how Project Aging, Inc. d/b/a Arlow processes “Consumer Health Data” (as defined below) subject to the Washington My Health My Data Act (MHMDA), the Nevada Health Data Privacy Act (NHDPA), or other applicable state consumer health privacy law.

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This Notice applies only to personal information that is considered “Consumer Health Data” under those laws. This Notice does not address or apply to information or practices that are not subject to these laws.

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The term “Consumer Health Data” as used in this Notice means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in these laws. Consumer Health Data does not included information that is considered deidentified under these laws or job applicant or employment information.
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We may modify this Notice at any time. All changes will be effective immediately upon posting to the Sites. Changes that we, in our sole discretion, determine are material will be conspicuously posted on the Sites or otherwise communicated to you.

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Our Privacy Policy (located at: https://www.arlow.ai/legal/privacy-policy) describes how we handle your personal information generally. Capitalized terms used but not defined in this CHDPP shall have the meaning in the Privacy Policy.

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1. Collection and Use of Consumer Health Data

The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, the information that you decide to share with us. Depending on applicable law and how you interact with Arlow, we may collect the following categories of Consumer Health Data:

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    • Individual health conditions, treatment, diseases, or diagnoses
    • Social, psychological, behavioral, and medical interventions
    • Health-related surgeries or procedures
    • Use of prescribed medication
    • Diagnoses, treatment, or medication
    • Data that identifies a consumer seeking health care services
    • Other information that may be used to infer, derive, or extrapolate data related to the above or other health information

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This Consumer Health Data may be collected when you create an account and access our services via our Sites or our App.

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This Consumer Health Data may be combined with identifiable information that we passively and automatically collect about you when you use our Sites or our App such as your IP address, device ID, or unique advertising IDs, and personal information that you may actively provide to us when interacting with our Sites or our App. We may combine this data as necessary to operate, secure, and provide the services, and not for advertising or data brokerage purposes.
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We may collect and use Consumer Health Data for the purposes outlined in the “How We Use Your Information” section in our Privacy Policy and consistent with applicable law. We will process Consumer Health Data in accordance with our policies and procedures.

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2. Sources of Consumer Health Data

The Consumer Health Data we collect depends on the context of your interactions with our Sites and our App and, in most cases, is information that you directly decide to share with us.

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As described further in our Privacy Policy, these sources may include:

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    • You and sources authorized to provide Consumer Health Data on your behalf (e.g., family members and care partners)
    • Your interactions with our Sites, our App, or otherwise
    • Your personal devices
    • Third parties that provide access to information you make available (e.g., social media)
    • Our business and marketing partners, who provide us with information about consumers who are viewing our content across websites or apps or selecting our services via our Sites and our Apps
    • From third-party sources (e.g., market research companies conducting non-clinical research)
    • From publicly available sources

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We also may collect and use additional categories of Consumer Health Data that are not in this CHDPP as consented by you.

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3. How Consumer Health Data May be Shared

We may share Consumer Health Data as described in the “Disclosure of Personal Information” section of our Privacy Policy and consistent with applicable law.

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In the event we process deidentified data, we agree to maintain and use deidentified data without attempting to reidentify a consumer except as permitted by law and will contractually obligate any recipients of such data to satisfy these criteria.

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4. How to Exercise Your Rights Regarding Consumer Health Data

You may have certain rights to your Consumer Health Data under applicable state law. These rights may vary depending on your state of residence. If you would like to exercise these rights, please contact our Privacy Officer with the information below.

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Access or Deletion Request: We may need to verify your identity to process your request. To confirm your identity, we may ask you to verify your identity with information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification) in accordance with applicable law. We will only use such additional information to verify your identity and for security or fraud-prevention purposes.

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Right to Appeal: If we decline or are unable to take action regarding your request, we will notify you by providing our reasons and will provide instructions for how you can appeal the decision.
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Depending on your data choices, certain services may be limited or unavailable. For example, we need to collect certain Consumer Health Data in order to provide relevant medication and appointment reminders, provide personalized recommendations about what you can do to maintain your health, provide a personalized care plan, etc. If you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to do so.
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5. Contact Us

If you have questions or concerns regarding this Policy, you may contact us:

By email at: privacy@arlow.ai

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