This Consumer Health Data Privacy Notice (“Notice”) supplements the Pinnacle Clinical Research (collectively, “Pinnacle,” “we,” “us,” or “our”) Privacy Notice (“Privacy Notice”) and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA).

 

Consumer Health Data We Collect

Sources of Consumer Health Data

Why We Collect and Use Consumer Health Data

Our Sharing of Consumer Health Data

Third Parties with Which We Share Consumer Health Data

How to Exercise Your Rights

Changes to This Notice

 

Consumer Health Data We Collect

 

As described in the Data We Collect  section of the Privacy Notice, the data we collect depends on the context of your interactions with Pinnacle and the choices you make (including your privacy settings), the information you provide to us, the clinical trials or studies you participate in or sign up for, the appointments you attend or sign up for, 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.

 

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.

 

• 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. For example, we collect your search queries on our website, which may include queries concerning nutrition, wellness, fitness, medical conditions, or other health-related topics.

 

• Other information that may be used to infer or derive data related to the above or other health information.

 

Sources of Consumer Health Data

 

As described further in the Data We Collect section of the Privacy Notice, 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.

 

Why We Collect and Use Consumer Health Data

 

We collect and use consumer health data for the purposes described in the How We Use Data  section of the Privacy Notice. 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 our services, ensuring the secure and reliable operation of our services and the systems that support them, improving the products, and other essential business operations that support the provision of our 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 Your Choices section of the Privacy Notice and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

 

Our Sharing of Consumer Health Data

 

We may share each of the categories of consumer health data described above for the purposes described in the Data We Collect section of the Privacy Notice. In particular, 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 share your content with third parties when you tell us to do so. If you make a purchase, we will share information about the transaction as necessary to process the payment, including protection against fraud. And we may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

 

Third Parties with Which We 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 (“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. A full list of specific affiliates and locations is available here.

 

• Government agencies. As described in our Privacy Notice, 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.

 

How to Exercise Your Rights

 

If you are covered by the MHMD 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 by contacting us via the contact information found in the Contact Information section in the Privacy Notice.

 

If your request to exercise a right is denied, you may appeal that decision by contacting us with the subject line “Appeal.” 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, the Nevada State Attorney General at https://ag.nv.gov/complaints/file_complaint/, or other regulatory authority as applicable.

 

Changes To This Notice

 

We may change our Notice and privacy practices.  New notices will be published on our website.  If changes are material, the Notice that was in place when you submitted personal data to us will generally govern that data unless you consent to the new Notice. Our Notice shows “effective” and “last updated” dates below. The effective date is the date the current version took effect. The last updated date is the date the current version was last substantively changed. 

 

Effective Date: 4/21/25

Last Update: 4/21/25