Our Privacy Notice describes how we handle your Personal Information generally. This supplemental Consumer Health Data Privacy Notice (“Supplemental Health Notice“) explains our practices with respect to “Consumer Health Data” as such term is defined by applicable laws, including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, each as amended from time to time and as and when they become effective, including any regulations thereunder (“U.S. Health Privacy Laws“).
Capitalized terms not explicitly defined in this Supplemental Health Notice shall have the meanings ascribed to them in our Terms of Service and Privacy Notice.
1. What is Consumer Health Data?
“Consumer Health Data” is a subset of Personal Information, and is broadly defined to mean Personal Information that is linked or can be reasonably linked to a consumer and that identifies past, present, or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as biometric data, information about use of non-prescription medication or use of health-related products.
Consumer Health Data does not include the following:
- Shopping habits or product interests related to general wellness or everyday health (not specifically tailored to your individual health status), unless this activity reveals something specific about your health.
- Publicly available information.
- Information protected by the Health Insurance Portability and Accountability Act and its implementing regulations.
- Personal Information that has been de-identified.
- Information about individuals with whom we have an employment relationship.
- For Nevada residents, shopping habits or product interests unless we use that information to identify your health status.
2. Categories of Consumer Health Data that We Collect
Celia may collect the following categories of Consumer Health Data, however, not all categories will be collected or received for every individual:
- Product Interests. This includes details about your interest in specific health, wellness, or personalized medicine products, such as when you view or purchase peptide therapies, supplements or other Products.
- Individual Health Conditions, Treatments, and Diseases. This includes information concerning your health status, medical history, symptoms, or relevant treatments, such as genetic predispositions, longevity goals, immune system support, or the use of Products related to metabolism, skin, gut, brain, or weight management.
- Social, psychological, behavioral and medical interventions. This includes information reflecting your engagement with holistic health interventions, including your participation in science-backed protocols, preventative care programs, or interest in behaviorally focused products like stress reduction or sleep support solutions.
- Diagnoses or diagnostic testing, treatment, or medication. This includes information regarding diagnostic activities or therapeutic interests, such as genetic testing, wellness assessments, personalized program recommendations or inquiries, and purchases concerning specific diagnostic or therapeutic Products.
- Bodily Function, Vital Signs, and Measurements. This includes details on your biological functions or vital measurements, including body composition, metabolic rate, immune resiliency, height, weight, or data collected through at-home genetic and health tests.
- Reproductive and Sexual Health Information. This includes information about your reproductive health or sexual well-being as shared through consultations, surveys, or when purchases related Products (e.g., Products supporting hormonal balance, libido, or fertility).
- Biometric Data. This includes information derived from photographs, videos, or other imagery submitted for product recommendations or participation in research or product evaluation, including analysis of skin, hair, facial features, or other biological markers.
- Genetic Information. This includes insights related to your unique genetic attributes, gathered through voluntary at-home genetic testing or personalized medicine initiatives to guide personalized wellness plans.
- Research Programs. This includes information you share when engaging in research initiatives or surveys, which may include aspects of your physical or mental health, medical background, and other wellness-related details.
3. How We Collect Consumer Health Data
As described further in the “Information We Collect” section of our Privacy Notice, we collect Personal Information (which may include Consumer Health Data) directly when:
- You voluntarily provide it to us (including when you purchase Products, join our marketing email lists, or volunteer information in connection with consultations or surveys).
- From your interactions with our Products and Services (including information collected from a device associated with you or your household and when you browse our websites).
- From third parties (including another company within our family of companies or from our business and marketing partners who provide us with information about consumers who are viewing our content or purchasing our Products), and
- From publicly available sources.
We may also infer or derive Consumer Health Data by analyzing other non-health-related Personal Information we hold about you or other consumers.
4. How We Use Your Consumer Health Data
We use the information described above to do the following:
- Provide our Services (including taking and processing your orders; shipping Products; communicating with you regarding your purchases; and sending you technical notices, updates, security alerts, and support and administrative messages);
- Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);
- Communicate with you (including responding to your requests, inquiries, comments, and suggestions);
- Personalize content (including tailoring content we send or display to you in order to provide you with information and resources we think will be relevant to you);
- Further our networking, marketing, and social strategies (including posting testimonials and communicating with you by email or SMS about programs, services, offers, promotions, and events);
- Serve and administer advertising (including serving you with relevant ads about our brands and programs, measuring and tracking the effectiveness of advertising campaigns, and carrying out other administrative and accounting activities with respect to ad campaigns);
- Conduct data analysis (including de-identifying and/or aggregating information and using it to perform research and provide statistical information and trend data)
- Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);
- Support our general business operations (including maintaining our business and legal recordkeeping); and
- Carry out any other purpose described to you at the time the information was collected.
We combine and associate Consumer Health Data collected or inferred about you from multiple sources or with other Personal Information about you to better achieve these purposes.
5. How We Share Your Consumer Health Data
We may disclose the categories of Consumer Health Data described above in the following circumstances:
- Companies under common control. We may share Consumer Health Data between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with Celia.
- Vendors and service providers. We may share Consumer Health Data with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf.
- Advertising and analytics partners. We may share your Consumer Health Data with other third parties that provide online analytics and advertising services, such as those that supply the pixels, cookies, tags, or other tracking technologies used on our Sites to collect real-time event and other usage data from and about our users for their own purposes (including to engage in advertising on behalf of themselves or others).
- Buyers or business transferees. We may share Consumer Health Data with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
- Professional advisors. We may also share your Consumer Health Data with our professional advisors, which include lawyers, accountants, licensed medical professionals, and other similar professional advisors.
- Legal requirements. We may share Consumer Health Data when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Consumer Health Data when we believe it is necessary to protect our rights and property, to protect the safety of our users, and to defend against legal liability.
- Consent. We may share Consumer Health Data with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information. For example, if you request information about a clinical trial, we will share your Consumer Health Data with the clinical trial sponsor as necessary to facilitate your request.
- De-identified/aggregate information. We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. Additionally, we may use such information to support the design and analysis of clinical trials, evaluate the performance of our products, and enhance our understanding of user experiences. Any de-identified data used in research will not be associated with personal identifiers and will be solely for scientific and development purposes.
6. Your Rights and Choices
You have a variety of rights and choices with respect to your Consumer Health Data:
- Right to know. You have the right to know if we are collecting, using, or disclosing your Consumer Health Data, to access that consumer health data, including receiving a list of the entities and affiliates with whom we have shared or sold your information, though currently we do not sell or share your Consumer Health Data with Third Parties or Affiliates.
- Right to delete. You have the right to request that we delete your Consumer Health Data.
- Right to withdraw consent. Where the collection or use of your Consumer Health Data is necessary for us to provide a Product or service you have requested from us, we may collect and use your Consumer Health Data without your consent. If we collect or use your Consumer Health Data for other purposes, however, we will obtain your consent for such processing, where the law requires us to do so. If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. For cookie-related Consumer Health Data, you can do this by using the cookie preferences settings on our Sites or Apps or by emailing us at privacy@celia-rx.com. Your actions apply only to the browser or device you use to interact with our Sites, not to other devices or browsers. If you clear your cookies or change your preferences on a particular browser or device, or use another browser or device to interact with our websites and mobile applications, you may need to withdraw consent using these tools again.
7. How to Exercise Your Rights
To exercise these rights, please contact us at privacy@celia-rx.com. We will authenticate your requests and process them as required by law. Please allow up to 45 days for a response. If we deny your request, you may appeal that denial. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:
We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services.
8. Changes to this Supplemental Health Notice
We may update this Supplemental Health Notice from time to time to reflect changes in our practices or in the law. If we make changes to this notice, we will post the updated Supplemental Health Notice on our website and indicate when it was last revised. You are advised to review this notice periodically to stay informed of our practices. If we make material changes, we may provide you with additional notice, such as posting a statement on our homepage or sending you an email notification, if we have your email address on file. Your continued use of the Services after the revised Supplemental Health Notice has become effective indicates that you have read, understood, and agreed to the current version of this Supplemental Health Notice, to the extent permitted by law.
9. Contacting Us
If you have any questions about this Supplemental Health Notice or how we protect your Consumer Health Data, please contact us at privacy@celia-rx.com or you may write to us at 405 Elizabeth Street, Austin TX 78704.
