Consumer Health Data Privacy Policy
This Consumer Health Data Privacy Policy (“CHD Policy”) supplements Glo’s Privacy Policy and applies specifically to information that qualifies as “consumer health data” under applicable state laws — including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, and Connecticut’s Data Privacy Act (collectively, the “CHD Laws”).
Capitalized terms not defined in this CHD Policy have the meaning given to them in our Privacy Policy. If you have questions about how this CHD Policy relates to our broader Privacy Policy, please refer to Section 4 (Health Information & HIPAA) of that Policy or contact us using the details in Section 8 below.
1. Scope of This Policy
The CHD Laws define “consumer health data” broadly to include information that is linked or reasonably linkable to a consumer and that identifies the consumer’s physical or mental health status — even if that information would not otherwise be considered medical or health information under laws like HIPAA.
Because Glo’s Services involve health-related questionnaires, telehealth consultations, and prescription medications, certain information you provide to us may qualify as consumer health data under these laws, regardless of whether it is also protected health information under HIPAA.
2. Categories of Consumer Health Data We Collect
Depending on how you use the Services, we may collect the following categories of consumer health data, as defined under the CHD Laws:
3. Sources of Consumer Health Data
As described in our Privacy Policy, we may collect consumer health data from the following sources:
- Directly from you for example, through intake questionnaires, calculator tools, and communications with your Provider;
- Automatically through your use of the Services such as which calculators or articles you interact with;
- From healthcare partners including Providers, pharmacies, and laboratories involved in your care; and
- From other third parties such as identity verification or insurance partners, where applicable.
4. Why We Collect This Information
Subject to applicable law, and as directed by you or with your consent where required, we collect and use consumer health data to:
- Provide and manage the Services, including facilitating consultations and prescriptions;
- Operate and improve our tools, such as the BMI, BMR, TDEE, and protein calculators;
- Communicate with you about your care, orders, and account; and
- Comply with our legal obligations, including recordkeeping requirements applicable to healthcare services.
We do not use consumer health data for advertising or marketing purposes without your consent, where required by applicable law.
5. How and With Whom We Share It
We may share the categories of consumer health data described above, subject to applicable law and your consent where required, with:
- Healthcare Providers and pharmacies — to deliver the care and medications you’ve requested;
- Service providers — vendors who support our operations under contracts limiting their use of this information;
- Insurance partners — if you choose to use insurance for your treatment;
- Regulators and legal authorities — where required to comply with law or to protect the rights and safety of Glo, our users, or the public; and
- Successors in a business transaction — such as a merger or acquisition, subject to confidentiality protections.
We may also create aggregated or de-identified data from consumer health data for example, the community-level statistics shown on our GLP-1 Supply Tracker which does not identify any individual and is not considered consumer health data once de-identified.
We do not sell consumer health data, and we do not share consumer health data with third parties for the purpose of targeted advertising, except where you have provided affirmative consent as required by applicable law.
6. Your Rights & How to Exercise Them
If you are a resident of a state with an applicable CHD Law, you may have the right to:
- Confirm whether Glo is collecting, sharing, or selling your consumer health data;
- Access the consumer health data we have collected about you;
- Delete your consumer health data, subject to certain legal exceptions (such as records we are required to retain);
- Withdraw consent to the collection or sharing of your consumer health data; and
- Correct inaccuracies in your consumer health data.
To exercise any of these rights, please contact us at privacy@glo.com or submit a request through our privacy request form. We may need to verify your identity before processing your request. We will never ask you for your account password to verify your identity.
7. Updates to This Policy
We may update this CHD Policy from time to time to reflect changes in the law, our data practices, the Services, or technology. The “Last updated” date at the top of this page reflects the most recent revision. If we make a material change, we will provide notice as required by applicable law. Your continued use of the Services after such notice constitutes acknowledgment of the updated CHD Policy.
8. Contact Us
If you have questions about this CHD Policy or how Glo handles consumer health data, please reach out:
Glo Health, Inc.
Email: info@glo.com
Phone:(xxx) xxx xxxx