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Color Health Consumer Health Data Privacy Policy

Last Updated: June 9, 2025

 

Application

This Consumer Health Data Privacy Policy (“CHD Policy”) applies to Color Health, Inc. and its affiliated entities (“Color,” “we,” “us,” or “our”) and governs how we collect, use, and share your “Consumer Health Data,” as such term is defined under Washington’s My Health My Data Act and other U.S. Consumer Health Data privacy laws, as amended, including any regulations thereunder (“CHD Laws”).

This CHD Policy does not apply to “Protected Health Information” (“PHI”) governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and any other data exempted by CHD laws. When we act as a Covered Entity or Business Associate under HIPAA, our uses and disclosures of PHI are governed solely by our HIPAA Notice of Privacy Practices. This CHD Policy supplements Color’s Privacy Notice.

In the event of a conflict with any other privacy policy or notice, other than express notice given at the time of collection, this CHD Policy shall govern with respect to Consumer Health Data.

Categories of Consumer Health Data Collected

The categories of Consumer Health Data that we collect may include:

  • Personal Data linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future health status including, but not limited to: (i) individual health conditions, treatment, diseases, or diagnosis; (ii) social, behavioral, and medical interventions; (iii) health-related surgeries or procedures; (iv) use or purchase of prescribed medication; (v) bodily functions, vital signs, or symptoms; and/or (vi) measures of the information the data described in (i)-(v)
  • Diagnoses or diagnostic testing, treatment, or medication
  • Reproductive information
  • Genetic data
  • Data that identifies a consumer seeking health care services
  • Consumer Health Data derived or extrapolated from non-health data that can be used to associate or identify a consumer with the above-listed categories

Sources of Consumer Health Data
We collect Consumer Health Data through the following means:

  • Directly from you, through account registration, lab testing services, telehealth interactions, and communications with Color
  • Automatically, via cookies, pixels, and other tracking tools on our websites and mobile apps
  • From third parties, such as insurance providers, telehealth vendors, or authorized representatives

We may also infer Consumer Health Data based on your activity on our platforms.

How We Use Consumer Health Data with Third Parties and Affiliates

We use Consumer Health Data only as permitted by applicable law and as needed to provide and improve our services. Uses may include:

  • Delivering clinical or digital health services and features you have requested
  • Coordinating care, including lab testing and follow-up communication
  • Operating and improving our platforms and mobile applications
  • Complying with legal obligations and public health requirements
  • Conducting analytics, performance testing, and service optimization
  • Communicating with you regarding your services, health-related results, and optional programs
  • With your consent, conducting marketing or enrolling you in optional services
  • Creating de-identified or aggregated information for research, consistent with applicable law and our Notice of Privacy Practices

How We Share Consumer Health Data with Third Parties and Affiliates

We share Consumer Health Data with third parties in limited circumstances, as follows:

  • Vendors that are classified as “processors” under the CHD Laws, which process Consumer Health Data to assist us in providing products and services requested by consumers, and for the other purposes described in this CHD Policy
  • Color’s agents and contractors who assist us with the processing purposes described in this CHD Policy
  • Assignees or potential assignees as part of an acquisition, merger, asset sale, or other transaction where another party assumes control over all or part of our business
  • As legally required, to courts, regulators, or law enforcement upon valid request
  • Other parties with your consent

Categories of Consumer Health Data We Share

The categories of Consumer Health Data that we share may include the following:

  • Personal Data linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status
  • Data that identifies a consumer seeking health care services
  • Consumer Health Data derived or extrapolated from non-health data that can be used to associate or identify a consumer with the above-listed categories

For example, we may share these data categories with third parties (website analytics) so our content may be included in search results.

Your Consumer Health Data Rights

Subject to applicable law, consumers who are provided rights under CHD Laws may have the following rights related to their Consumer Health Data:

  • Right to confirm processing of Consumer Health Data and access to such data
  • Right to delete
  • Right to withdraw consent (from processing which requires your consent)
  • Right to appeal our refusal to act on a request within a reasonable time after you receive our decision. You may appeal our decision regarding your request by following the instructions in our response to your request. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at http://www.atg.wa.gov/file-complaint

We may limit your request as necessary for us to complete or document a Direct Purpose or Special Purpose.

You may request to exercise your Consumer Health Data rights by contacting us at the information provided below. Please note, as required by CHD Laws, we take commercially reasonable efforts to authenticate your request before we process your request. If we believe we need further information to authenticate your request, we may ask you to provide additional information to us.

We will respond to your Consumer Health Data rights requests pursuant to the requirements of CHD Laws free of charge, up to twice annually. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

Additional Disclosures

We do not allow third parties to collect or use Consumer Health Data over time and across different Internet websites or online services.

We will retain and use your Consumer Health Data for the length of time needed to carry out the purposes outlined in this CHD Policy and in accordance with our record retention policies.

Changes to This CHD Policy

We may update this CHD Policy periodically to reflect changes in legal requirements or our services. Material changes will be communicated as required by law and reflected by a new “Last Updated” date at the top of this page.

Contact Us

If you have any questions about our privacy practices or this CHD Policy, or to exercise your rights as detailed in this CHD Policy, please contact us at:

 

Color Health, Inc.
Attention: Legal Department
831 Mitten Rd.
Burlingame, CA U.S.A., 94010
Email: privacy@color.com

Color is committed to making our website’s content accessible and user friendly to everyone. If you are having difficulty viewing or navigating the content on this website, or notice any content, feature, or functionality that you believe is not fully accessible to people with disabilities, please call our Support team at (844) 352-6567 or email support@color.com with “Disabled Access” in the subject line and provide (a) a description of the specific feature you feel is not fully accessible, or (b) a suggestion for improvement.

We take your feedback seriously and will consider it as we evaluate ways to accommodate all of our clients and our overall accessibility policies. Additionally, while we do not control vendors, we strongly encourage vendors of third-party digital content to provide content that is accessible and user-friendly.