VerdaMD, LLC

Consumer Health Data Privacy Policy

Last updated: August 14, 2026

This Consumer Health Data Privacy Policy supplements the Privacy Policy and applies to personal data defined as "consumer health data" subject to the Washington State My Health My Data Act ("MHMDA") and the Nevada Health Data Privacy Act ("NHDPA"). This Consumer Health Data Privacy Policy applies to individual consumers who are residents of the state of Washington or Nevada or individuals whose consumer health data is collected in the state of Washington or Nevada. In the event of a conflict between any other policy, statement, or notice and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy will control as to Consumer health data collected under MHMDA or NHDPA.

1. Consumer Health Data We Collect

As described in the Personal Data We Collect About You section of the Privacy Policy, the data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services you use, your location, 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. "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.

Examples of consumer health data may include:

Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments (including surgeries, procedures, medications, or other interventions). For example, we may collect such information through surveys or other communication with you for research studies and improving product accessibility.
Measurements of bodily functions, vital signs, or characteristics, including photographs, which may also be considered biometric information under the MHMDA, the NHDPA, or other applicable state consumer health privacy law.
Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies.
Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person's health.
Other information that may be used to infer or derive data related to the above or other health information.

2. 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, from your interactions with our Services, from third parties, and from publicly available sources.

3. Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in the How We Collect Your Personal Data and Personal Data Collected Through and Use of Automatic Data Collection Technologies and Cookies sections of the Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the Services you have requested or authorized. This may include delivering and operating the Services and their features, personalization of certain Service features, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the Services, and other essential business operations that support the provision of the Services (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law -- for example, for advertising or marketing purposes. See the Choices About How We Use and Disclose Your Personal Data section of the Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

We may share each of the categories of consumer health data described above for the purposes described in the How We Use or Disclose Your Personal Data section of the Privacy Policy.

We may share consumer health data with your consent or as reasonably necessary to provide a product or service that you have requested or when we believe that doing so is necessary to comply with applicable law or respond to valid legal process. "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 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 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.

As necessary for the purposes described above, we share consumer health data with the following categories of third parties:

Service providers. Vendors or agents ("processors") working on our behalf may access consumer health data for the purposes described above. For example, companies we've hired to provide customer service support or assist in protecting and securing our systems and Services may need access to data to provide those functions.
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.
Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our Services and operate our business.
Government agencies. As described in our Privacy Policy, we disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
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.
Other users and individuals. If you use our Services to interact with other Users of the Service or other recipients of communications, we will share data, including consumer health data, as directed by you and your interactions.
The public. You may select options available through our Services to publicly display and disclose certain information, such as your profile, demographic data, content and files, or geolocation data, which may include consumer health data.

6. Sales of Consumer Health Data

The 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 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. As required by law, we only sell consumer health data after we have obtained a valid authorization from the consumer whose consumer health data is involved in the sale. If you have previously authorized us to sell your consumer health data, you can revoke that authorization at any time by contacting us at support@verdamd.com for information on how to revoke your authorization.

7. How to Exercise Your Rights

If you are covered by the MHMDA, the NHDPA, or other applicable consumer health privacy law then you may have certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in the Choices About How We Use and Disclose Your Personal Data section of the Privacy Policy. For example, depending on the Service you use, you can access and make choices about your data through product controls. You can also access and clear some of your data through your web browser. And if you want to access or control consumer health data processed by us that is not available via those tools or directly through the Service you use, you can always contact us at support@verdamd.com. You may submit a rights request, free of charge, up to two times in a 12-month period, or as otherwise required by applicable law. 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 our support team at support@verdamd.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](https://www.atg.wa.gov/file-complaint), the Nevada State Attorney General at [https://ag.nv.gov/complaints/file_complaint/](https://ag.nv.gov/complaints/file_complaint/), or other regulatory authority as applicable.

8. 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, do not hesitate to contact us at:

Phone: 305-417-9371

Website: www.verdamd.com

Email: support@verdamd.com

Postal Address:

VerdaMD, LLC

Attn: Legal

485 Brickell Ave Suite 3109, Miami, FL 33130

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