WASHINGTON CONSUMER HEALTH DATA PRIVACY POLICY 

Last Updated: December 1, 2025

This Washington Consumer Health Data Privacy Policy supplements the Network of Advanced Specialty Healthcare Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (“MHMDA”). This Washington Consumer Health Data Privacy Policy only applies to individual consumers who are residents of the state of Washington, or individuals whose consumer health data is collected in the state of Washington. 

“Consumer health data” means personal information that is linked or reasonably linkable to a particular individual and that identifies that individual’s past, present, or future physical or mental health status. However, the following categories of information are not consumer health data and not covered by this Washington Consumer Health Data Privacy Policy: 

  • Protected Health Information (“PHI”), as defined by the Health Insurance Portability and Accountability Act (“HIPAA”); 
  • Health care information collected, used, or disclosed in accordance with WA Revised Code § 70.02 (“Medical Records – Health Care Information Access and Disclosure”); 
  • Publicly available information; 
  • Deidentified data; or 
  • Information otherwise excluded from the scope of Washington MHMDA. 

Please note that data practices concerning Protected Health Information collected by Network of Advanced Specialty Healthcare and its affiliates are described in the terms and privacy disclosures specific to those services, namely, this Notice of Privacy Practices. 

I. Categories of Consumer Health Data We Collect 

As described in the Privacy Policy, the data we collect depends on the context of your interactions with Network of Advanced Specialty Healthcare and the choices you make (including your privacy settings), the products and features you use, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data.  

We may collect the following categories of consumer health data with your consent or to the extent necessary to provide a product or service that you requested. We only collect the categories of consumer health data described in this Washington Consumer Health Data Privacy Policy. 

  • Individual health conditions, treatment, diseases, or diagnosis 
  • Social, psychological, behavioral, and medical interventions 
  • Health-related surgeries or procedures 
  • Use or purchase of prescribed medication
  • Bodily functions, vital signs, symptoms, or measurements of other health data  
  • Diagnoses or diagnostic testing, treatment, or medication 
  • Gender-affirming care information 
  • Reproductive or sexual health information 
  • Genetic data 
  • Data that identifies a consumer seeking health care services 
  • Any other information used to associate or identify an individual with any category of health data that is derived or extrapolated from nonhealth information (such as proxy, derivative, inferred, or emergent data by any means, including algorithms or machine learning) 

Examples of consumer health data may include: 

  • Medical information you choose to provide via our Contact Us form. 
  • Other information that may be used to infer or derive data related to the above or other health information

II. Sources of Consumer Health Data 

As described further in the Privacy Policy, we collect personal data (which may include consumer health data) directly from you and from your interactions with our products and services, including our website. We may also collect personal data (which may include consumer health data) from our physician and pharmacist partners and service providers and from publicly available sources.‍

III. Purposes for Collecting and Using Consumer Health Data 

We only collect and use consumer health data for the purposes described in this Washington Consumer Health Data Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to communicate with you and to provide you with the products and services you have requested. We may also collect and use consumer health data for the following purposes: 

  • Operate, maintain, supervise, administer, and enhance our website, including monitoring and analyzing the effectiveness of content on the services, aggregate site usage data, and other usage of the services such as assisting you in completing the registration process. 
  • Provide our products and services to you, in a custom and user-friendly way. 
  • Provide you with information, products, or services that you request from us or that may be of interest to you. 
  • Promote and market our services to you. For example, we may use your personal information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. You can opt-out of receiving these e-mails at any time. 
  • To provide you notices about our provision of our services. 
  • Contact you in response to a request. 
  • To notify you about changes to our services or any products or services we offer or provide through them. 
  • Fulfill any other purpose for which you provide it. 
  • Anonymize and aggregate information for analytics and reporting. 
  • To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations. 
  • Authenticate use, detect fraudulent use, and otherwise maintain the security of our website and the safety of others. 
  • To administer surveys and questionnaires. 
  • To provide you information about goods and services that may be of interest to you, including through newsletters. 
  • Any other purpose with your consent. 

IV. Sharing of Consumer Health Data 

We may share consumer health data with your consent or as reasonably necessary to provide a product or service that you have requested. “Share” under the Washington MHMDA means to release, disclose, disseminate, divulge, make available, provide access to, license, or otherwise communicate consumer health data to a third party or affiliate. However, “share” does not include (i) disclosure of consumer health data to provide goods or services in a manner consistent with the purpose for which we collected the consumer health data; (ii) disclosure to a third party with whom you have a direct relationship when the disclosure is for the purpose of providing a product or service for you if we maintain control and ownership of the data, and the third party uses the data only at our direction and consistent with your consent and for the purpose for which it was collected; or (iii) disclosure or transfer of consumer health data to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in compliance with the Washington MHMDA. The term “third party,” as used in this Washington Consumer Health Data Privacy Policy, means a person who is not a consumer, an entity regulated under the Washington MHMDA, a processor, or an affiliate of an entity regulated under the Washington MHMDA. 

We may share consumer health data to the following categories of third parties and specific affiliates: 

  • Business partners, such as those providing analytics and technology services; and 
  • To other third parties (such as law enforcement or government regulators) where required by, or otherwise permitted by, law 

V. How to Exercise Your Rights 

If you are covered by the Washington MHMDA, then you have certain rights with respect to consumer health data, including the right to confirm if Network of Advanced Specialty Healthcare is collecting, sharing, or selling your consumer health data, and the right to access, delete, or withdraw consent for the collection and/or sharing of such data, subject to certain exceptions. You can request to exercise such rights by contacting us via email at inquiries@nashcares.com. You may submit a rights request, free of charge, up to two times per year. We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If your request to exercise a right is denied, you may appeal that decision by contacting us at  inquiries@nashcares.com. 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. 

VI. Sales of Consumer Health Data 

The Washington MHMDA defines a “sale” as the exchange of consumer health data for monetary or other valuable consideration, excluding exchange (i) to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of our assets that complies with the requirements and obligations in the Washington MHMDA; or (ii) by us to a processor when such exchange is consistent with the purpose for which the consumer health data was collected and disclosed to the consumer. 

We do not sell consumer health data.

VII. Contact Us 

If you have any questions, concerns, complaints or suggestions regarding this Washington Consumer Health Data Privacy Policy or otherwise need to contact us, you may contact us toll-free: (833) 833-6240 or via email:  inquiries@nashcares.com or through the Contact Us page on our website.