NOWINCLUDED

CONSUMER HEALTH DATA PRIVACY NOTICE

Last Updated Date: 1/23/2026

This Consumer Health Data Privacy Notice (“Notice“) describes Acclinate Inc.’s practices (“Acclinate,” “we,” “us,” or “our”) for collecting, using, disclosing, and processing “consumer health data,” as defined in the Washington My Health My Data Act and other similar applicable laws.

This Notice supplements our Privacy Policy and applies to consumer health data that we collect through our digital or online properties or services that link to this Notice (including as applicable, our website, mobile application, our NOWINCLUDED health resource community platform, and social media pages) as well as our marketing activities, in-person events, community outreach efforts, and other activities described in this Notice (collectively, our “Services”). This Consumer Health Data Privacy Policy applies to the extent required by applicable law.

Please read this Notice carefully to understand our policies and practices regarding how we treat consumer health data. If you do not agree with our policies and practices described in this Notice, please do not use our Services, and do not provide us with your consumer health data.

Consumer Health Data We Collect

We may collect or receive the categories of consumer health data listed below. Not all categories will be collected or received for every individual. Information identifying a health condition, treatment, disease, or diagnosis such as breast cancer screening information, results of blood and other testing panels, tobacco, smoking, and alcohol use and history, individual and family health history, interest and participation in clinical trials, family planning and pregnancy, and information about environmental exposures;
Information identifying social, psychological, behavioral, and medical interventions;
Information identifying health-related surgeries or procedures such as breast cancer screening results;
Information relating to bodily functions, vital signs, symptoms, or measurements of the information described herein such as results of blood and other testing panels;
Information identifying diagnoses or diagnostic testing, treatment, or medication such as results of blood and other testing panels, individual and family health history, and interest and participation in clinical trials;
Reproductive or sexual health information such as family planning and pregnancy care;
Information identifying precise location, if that information could reasonably indicate an attempt to acquire or receive health services or supplies;
Information that identifies an individual’s intention to seek health care services such as information about health care appointments, care that an individual has sought or received, prescription medications, and vaccinations; or
Information that we derive or extrapolate from data that is not consumer health data, and then use to associate an individual to the information listed above. This also includes inferences we may make based on an individual’s interest in certain health topics.

We also collect demographic information such as age, gender, race, ethnicity, and income, and contact information such as address and phone number, which we may associate with consumer health data of an individual. Also, we may associate other information and data collection in connection with an individual’s use of our Services, which we may associate with consumer health data of the individual.

How We Use Consumer Health Data

In general, we collect consumer health data as necessary to provide our Services, operate our business, and provide information that you request from us. This includes the following:

Create and administer user accounts in our Services.
Provide, operate, improve, maintain, and protect our Services.
Provide health information (including articles, events, health education materials) and relevant clinical research opportunities to our users and members.
Evaluate if an individual is eligible to participate in a clinical trial via a clinical trial pre-screening questionnaire.
Store, transcribe, and analyze Chatbot information.
Provide technical and other support.
Facilitate actions users take in the Services.
Send Services and company updates, marketing communication, and other information about our NOWINCLUDED community platform, Acclinate, our Services, and products and services of third parties, that we think users may be interested in, including information about clinical trials.
Conduct research and analysis, and monitor and analyze trends and usage.
Enhance or improve user experience, our business, and our Services, including the safety and security thereof.
Personalize our Services.
Communicate and respond to inquiries, including to improve our responses.
Suggest resources and information that we think users might be interested in.
Send push notifications through the App.
Operate our business and perform any other function that we believe is necessary to protect the security or proper functioning of our Services.
As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
Enforce contracts and applicable Terms of Use, including investigation of potential violations thereof.
Detect, prevent, or otherwise address fraud, security or technical issues.
Protect against harm to the rights, property or safety of Acclinate, our Services, our Community, our users, customers, or the public as required or permitted by law.

Additionally, we may deidentify or anonymize consumer health data so that it cannot reasonably be reidentified by us or by a third-party, and we may use this deidentified data for any reason permitted by applicable law. If we deidentify information that was originally based on consumer health data, we store and use that information in deidentified form and will not attempt to reidentify the data, except as otherwise permitted under applicable law.

Consumer Health Data Sources

We collect consumer health data from the following sources:

Directly from users, such as when users interact with us or our Services.
Users’ devices when visiting or interacting with our websites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our websites or services.
Our business and marketing partners, who provide us with information about users who are viewing our content over time and across other websites and online services.

How We Share Consumer Health Data

We do not sell consumer health data.

We may share or disclose consumer health data to processors, service providers, and contractors that help us provide products and services to our users. Such third parties are permitted to use consumer health data to provide services to us and in accordance with applicable law.

We instruct our processors, service providers, and contractors to only use consumer health data as permitted by our contracts with them and consistent with applicable law.

We may also disclose consumer health data as permitted by applicable law, including:

With users’ consent.
Through user-facilitated actions. For example, users may post their own consumer health data to public areas of our NOWINCLUDED platform, such as by sharing a story that discusses consumer health data. Additionally, certain features in the Services may enable users to participate and interact with each other such as by joining health circles. Users that interact with each other may, in some cases, be able to save that content or copy it outside of th4e Services – so users should not share any information or content that they would not want another user to save or share.
To comply with a legal requirement, law, subpoena, judicial proceeding, court order, governmental request, or legal process.
To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities.
In connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation or dissolution of Acclinate, including the evaluation thereof;
To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others.
To protect vital interests, including health and safety.

Your Privacy Rights

Users have the following rights with respect to their consumer health data:

Right to confirm and access consumer health data, including a list of all third parties and affiliates with which we have shared your consumer health data. By exercising this right, users can confirm whether we are collecting or sharing their consumer health data and request a list of third parties with whom we have shared their consumer health data, and an email address or other online mechanism that users may use to contact them. Note that we do not sell consumer health data.
Right to correct consumer health data.
Right to withdraw consent from collection or sharing of consumer health data.
Right to delete consumer health data.

Users can delete, access, and correct most of their consumer health data directly through their accounts in the Services. Users may also submit a request to exercise privacy rights by emailing us at [email protected]. We may require additional information to verify the requestor’s identity before acting on the request. We may deny requests that we cannot verify, or as permitted by applicable law. We will respond to requests within timelines permitted by applicable law.

Users may appeal our refusal to take action on a privacy rights request. To make an appeal please Email us at [email protected].

Changes to this Notice

We may update this Notice from time to time, including in response to changing laws, regulations, and industry practices. We reserve the right to modify, add or remove portions of this Notice at our discretion. If we make changes to this Notice, we will post the updated version on this page. If we make material changes to this Notice, we will provide notice in writing (including by email) where required under applicable law.

Contact Us

If you have any questions about this Notice or data protection at Acclinate, you can contact our Data Protection Officer by e-mail: [email protected].