Consumer Health Data Privacy Policy

Effective date: 17th December 2024

Last updated: 17th December 2024

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This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Astron Health Limited (“Astron,” “we,” “us,” or “our”) processes “Consumer Health Data,” as that term is defined under applicable state privacy law, about consumers who reside in the states of Nevada, Washington, and any other applicable U.S. jurisdiction in connection with our Platform, https://astron.health including any other media form, media channel, mobile Platform, or mobile application related or connected thereto (collectively, the “Site”) and the associated treatment and counseling services facilitated through the Site (“Services”), as well as any functionalities, applications, or platforms that we offer or may develop in the future where this Health Data Policy is made available (collectively with the Services, the “Platform”). Please carefully read this Health Data Policy as it contains important information concerning your Consumer Health Data and how we use it.

Consumer Health Data is personal information that we collect about you that may identify your past, present, or future physical or mental health status.

This Health Data Policy relates only to Consumer Health Data. It does not describe how we process your personal information. For more details about our information practices with respect to personal information, please refer to our Privacy Policy.

Information We Collect

We may collect the following categories of Consumer Health Data to the extent they are relevant to your care:

Individual health conditions, treatment, diseases, or diagnoses;
Social, psychological, behavioral, and medical interventions;
Health related surgeries or procedures;
Use or purchase of prescribed medications;
Bodily functions, vital signs, symptoms, or measurements;
Diagnoses or diagnostic testing, treatment, or medication;
Biometric data;
Genetic data;
Information that could identify your attempt to seek health care services;
Any inference based on the above categories or derived or extrapolated from non-health information that identifies your past, present, or future physical or mental health status.

How We Collect Your Information

We collect Consumer Health Data from the following categories of sources:

Directly from you when you share it with us through the Platform;
From third parties (such as your health care professionals) that may be involved with your care; and
Through third parties and service providers that support the Platform. This may include the use of cookies, pixels, web beacons, and similar technologies to collect information about you over time and across different websites, including the Platform.

How We Use Your Information

We collect, process, and disclose Consumer Health Data for the following business purposes:

To provide, operate, maintain, and protect our Platform;
To analyze and improve our Platform, including developing new products or services;
To identify potential research opportunities and to facilitate and conduct research for potential publication pursuant to your authorization and/or informed consent in accordance with applicable law;
To communicate with you, respond to your inquiries, and to send you information by email, postal mail, telephone, text message, notifications, or other means about our products and services;
To promote and conduct educational or promotional events, including those that may be in person and to support our marketing and advertising activities, including measuring and optimizing our advertising;
To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences across our Platform;
To protect the security or integrity of the Platform, including to perform security analyses to verify that the Platform is working properly;
To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Consumer Health Data held by us about our customers is among the assets transferred.

How We Disclose Your Information

We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties:

As legally required in relevant legal proceedings and otherwise to the extent required or authorized by applicable law;
With your health insurance company, pharmacy, and healthcare professionals and their service providers as relevant to your treatment and related payment and care operations;
To clinical research organizations, researchers, and healthcare institutions we collaborate with for research and development activities, in compliance with applicable law;
Service providers, contractors, and other third parties that support our business operations and the Platform;
Third parties within the context of a merger or similar business transaction; and
Other third parties at your express direction.

Your Privacy Rights

Depending on your place of residency, you may have some or all of the following rights regarding your Consumer Health Data, subject to applicable law and certain exceptions:

Right to Confirm and Access: If you ask us, we will confirm whether we are collecting, sharing, or selling your Consumer Health Data. At your request, we will provide a list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.
Right to Correct: If your Consumer Health Data that we maintain is inaccurate and you would like us to correct it, you may request that we make changes to it.
Right to Withdraw Consent: Where we have relied on your consent or authorization for certain processing of your Consumer Health Data, you may withdraw that consent or authorization at any time.
Right to Delete: You may request that we delete Consumer Health Data that we maintain about you.
Right to Appeal: If we deny your request to exercise any of the above rights, you may request to appeal this decision.

To exercise any of the above rights, you or your authorized agent may do so by following instructions in “Contact Us” below. In order to process your request, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as most recent interaction with us, if applicable.

We do not “sell” your Consumer Health Data for monetary compensation. We share your name, email address, and approximate location (such as town/city/country) during and after your sign up for a consultation with us so that we can measure the effectiveness of and optimize our advertising efforts on third-party websites. This practice may be interpreted as a “sale” of Consumer Health Data in some U.S. jurisdictions.

Updates to this Policy

We may update this Health Data Policy from time to time and notify you in accordance with the law, which may include email or other notice posted to the Platform. Any changes to this Health Data Policy will become effective when we notify you of the changes. Your use of the Platform following any such updates will constitute your acceptance of such updates.

Contact Us

For questions about our Health Data Policy, to make choices about receiving promotional communications, or to request to exercise a right described in this Health Data Policy, you can contact us by emailing our Data Protection Officer at ben@astron.health.

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