Last Updated: May 13, 2024
This Consumer Health Data Privacy Policy (“WA Consumer Health Data Privacy Policy”) supplements our Website Privacy Policy (“Privacy Policy“) and applies solely to individuals who are Washington residents; or (b) individuals whose consumer health data is collected in Washington (collectively “Washington Consumers”)
Your privacy is important to us. Karneth Consulting LLC dba Sangha Healing (“we,” “us,” “our,” and “Sangha Healing”) respects the privacy of every person who visits our website www.SanghaHealing.com (our “Website”), and we are committed to protecting privacy through compliance with our Privacy Policy and this WA Consumer Health Data Privacy Policy. Our Website is for individuals seeking a community that provides holistic healing possibilities through connection and education. (collectively the “Services”). Our Website connects individuals accessing our Website (each a “User” and collectively “Users”) to independent healers who offer a comprehensive range of healing modality services (“Healers”) In connection with providing you access to our Website and Services we may collect certain consumer health data (as defined below).
This WA Consumer Health Data Privacy Policy describes how we collect, use, disclose, and otherwise process your consumer health data in connection with your use of our Website and explains your rights regarding your consumer health data and how you can exercise those rights. This WA Consumer Health Data Privacy Policy does not apply to information collected by us offline or through other sources or information collected by third parties.
1. What is Consumer Health Data
The Washington My Health, My Data Act (“MHMDA”) broadly defines consumer health data as personal information that is linked or reasonably linkable to a Washington Consumer and that identifies the Washington Consumer’s past, present, or future physical or mental health status.
2. Consumer Health Data We May Collect
As described in the Personal Information and Sensitive Personal Information We May Collect About You section of our Privacy Policy, the personal information we collect about you depends on the purpose and nature of your interactions with us on our Website and on what Services and features you use on our Website. It will also depend on the choices you make (including your privacy settings), your location, and Appliable Law. The personal information we collect may include consumer health data within the meaning of the MHMDA, including:
- Information about your physical or mental health status including, (i) information about individual health conditions, treatment, diseases, or diagnosis; (ii) social, psychological, behavioral, and medical interventions; (iii) health-related surgeries or procedures; and (iv) reproductive or sexual health information. For example, we may collect this information from you when you respond to quizzes or surveys on our Website or when you research these topics on our Website.
3. How We May Use The Consumer Health Data We Collect From You
We collect and use consumer health data for the purposes described in the How We May Use Your Personal Information section of our Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you access to the Services you have requested through our Website This may include:
- A purpose you direct. You direct us to collect, use, and/or disclose your consumer health data.
- Marketing to you. For example, this may include determining what products and Services you may be interested in; marketing products and Services to you.
- Enhancing your experience with us on our website. For example, this may include recommending products and Services based on preferences; delivering jurisdiction-specific Website content; tailoring your experience on our Website; and drawing inferences from your consumer health data to tailor your experience on our Website and identify the products you might be interested in.
- Legal and regulatory compliance. For example, this may include complying with applicable laws, regulations, and oversight obligations; for quality assurance; for internal and external audits and investigations; engaging with law enforcement and other governmental bodies; for litigation; for compliance with mutual policies and procedures, contracts, and oversight obligations; and enforcing contractual obligations and exercising contractual rights.
- Our internal purposes. For example, this may include conducting, managing, maintaining, and improving our products and Services; business operations and processes; security and privacy practices, which may include, but not be limited to detecting, investigating, and resolving potential vulnerabilities, data security, or privacy incidents; quality assurance; business continuity; systems, networks, applications, and databases, which may include, but not be limited to preventing, finding, and resolving software, hardware, or application bugs and issues.
4. How We May Disclose Your Consumer Health Data
We may share each of the categories of consumer health data described above for the purposes described in the section of the privacy statement.
We may share personal data, including consumer health data, with your consent, or as reasonably necessary, to provide any Service you have requested or authorized, as described above. For example, we may share your personal information with our Healers, and if you make a purchase, we will share information as necessary to process the payment, including protection against fraud. We may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.
Please note that we do not sell your consumer health data.
Third Parties With Which We May Share Consumer Health Data.
As necessary for the purposes described above, we share consumer health data with the following categories of third parties:
- Service providers. Vendors or agents working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to assist in protecting and securing our systems and Services may need access to data to provide those functions. We may also share your consumer health information with our Healers to facilitate identification of and access to appropriate Services.
- Business partners. We may share consumer health data with other companies, for example, where you use a service that is cobranded and jointly operated with another company, or where you use our Services to interact with another company.
- Government agencies. To respond to law enforcement requests, subpoenas, or other legal processes, or as otherwise required by law, by court order, or to respond to a governmental/regulatory request;
- Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
5. Your Rights and Choices
You have certain rights with respect to your consumer health data under MHMDA, including rights to access, delete, or withdraw consent from future collection or sharing, subject to certain exceptions. See the section on Rights and Choices You May Have About Your Personal Information in our Privacy Policy for more details on the rights and choices you may have regarding your personal information, including your consumer health data.
We will not discriminate against you for exercising any of your rights under this WA Consumer Health Data Privacy Policy. You have a right not to receive discriminatory treatment by us for exercising your privacy rights.
5.1. The Right to Know/Access the Personal Information We Collected And How We Shared Your Information.
You have the right to request a copy of, or access to, the consumer health data that we have collected about you.
5.2. Withdrawing Your Consent.
You have the right to withdraw consent for the collection and sharing of your consumer health data. If we seek your consent, we will provide you with a process for withdrawing it.
5.3. Right to Request Deletion of Personal Information.
You have the right to request that we delete any Personal Information we have collected from you. Subject to certain exceptions set out below, we will, on receipt of a verifiable request, delete your consumer health data from our records and direct any service providers to do the same. We will also notify all third parties with whom we have shared your consumer health data of your request to delete.
We may deny your deletion request if retaining the consumer health data is reasonably necessary for us (or our affiliates, processors, contractor(s), or third parties) to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under Washington state law or federal law; preserve the integrity or security of
systems; or investigate, report, or prosecute those responsible for any such action that is illegal under Washington state law or federal law.
Please also note that any request to delete collected consumer health data may impact your ability to interact with us or to use our Website for its intended purposes.
5.4. Exercising Your Rights and Choices.
You can exercise the rights set out in this section above by emailing us at [email protected]. In addition to providing the information we need to verify you or your authority, you must provide us with enough information so that we can understand, evaluate, and respond to your request.
5.5. Appealing Our Decision About Your Rights.
If we have denied your request to exercise your rights under the MHMDA, you may appeal our denial. Please submit your appeal request by contacting us at [email protected]. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
6. Changes to This WA Consumer Health Data Privacy Policy
We reserve the right, at any time, to add to, change, update, or modify this WA Consumer Health Data Privacy Policy. We reserve the right to provide data and privacy transparency as required by law. If we decide to change this WA Consumer Health Data Privacy Policy, we will notify you by posting a new policy through our Website and change the “Last Updated” at the top of this WA Consumer Health Data Privacy Policy. Any change, update, or modification will be effective immediately upon posting to our Website will apply to any consumer health data provided to us on and after that date. If we make material changes to the type of consumer health collected, or how we share, use or sell consumer health data, we will provide you with notice to the e-mail address you provided, if you provided one. It is important that you monitor this WA Consumer Health Data Privacy Policy and your e-mail for changes to this WA Consumer Health Data Privacy Policy. We may also request that you confirm you have read this WA Consumer Health Data Privacy Policy and any revised version before we provide you access to our Website. We will accept your continued use of our Website after we make changes to be acceptance of those changes.
Changes to the WA Consumer Health Data Privacy Policy will not affect our use of previously provided consumer health data.
7. Contact Us
If you have any questions about this WA Consumer Health Data Privacy Policy, the ways in which we may collect and use your consumer health data described in this WA Consumer Health Data Privacy Policy, or your choices and rights regarding such use, please feel free to contact us at [email protected].