This Consumer Health Data Privacy Notice explains how Claren Health, Inc., with its registered office at 470 Atlantic Ave Floor 12 Boston, MA 02210 (“Claren Health,” “we,” “us,” or “our”) collects, uses, shares, and protects consumer health data when you use the Claren Health website (clarenhealth.com) and our Services (as defined in our Terms of Service). It also outlines your rights and choices regarding this data. This notice supplements our general Privacy Policy.

1. What Consumer Health Data We Collect

When you use our Services, we may collect the following types of consumer health data:

• Individual health conditions, treatment, diseases, or diagnosis. We collect self-reported information through our Services, including information about your health, lifestyle and wellbeing. This may also include your height, weight, Body Mass Index, pregnancy status, and information about whether you have previously undergone surgeries or procedures, physical conditions, symptoms, data related to your weight, diet, lifestyle, medications (dosage, timing, frequency), lab results, images, and other information relevant to your care. Although we do not diagnose medical conditions, this information may reflect aspects of your health or perceived wellbeing and may be considered indicative of a health condition.
• Social, psychological, behavioral, and medical interventions. Based on your responses and how you interact with the Services, we may collect information about social, psychological, behavioral and/or medical routines related to your health, such as the amount and type of physical activity in which you engage, diet and eating behaviors, the use of medications and experiences with treatments such as physical therapy. These features are intended to support your ongoing health and wellness and to help facilitate communication with your healthcare provider.
• Health-related surgeries or procedures. If you choose to voluntarily share information about past or planned medical procedures or surgeries, that information may be collected and stored as part of your account data.
• Bodily functions, vital signs, symptoms, or measurements. You may choose to provide information about your physical state, such as physical symptoms, blood pressure, pulse rate or other bodily measurements.
• Any inferences of the above categories of health data derived or extrapolated from non-health information. We may draw limited inferences about your wellbeing based on how you interact with our Services. While this information is not health data on its own, it may suggest wellness needs. These inferences are used only to personalize your experience and are not used or shared for advertising or promotional purposes.

2. How We Collect Consumer Health Data

We collect consumer health data in the following ways: (a) directly from you; (b) from your use of the Services. Specifically, we collect consumer health data directly from you:

• When you fill out questionnaires or assessments.
• When you upload images or symptom information.
• When you interact with features of our Service.

We may also generate inferences from your usage of our Service, for example, if you use a certain feature frequently, we may suggest similar content.

3. Why We Use Consumer Health Data

We collect and use your consumer health data as necessary to provide you with the information and services you request through our Service to support your wellness, generate personalized insights, enable secure communication of your health information with your designated provider, and conduct scientific research relating to our offerings. Where required by applicable law, we will obtain your consent before collecting or using your consumer health data for purposes beyond what is necessary to provide the products or services you have requested. This includes:

• Helping you manage your care. We use your data to deliver personalized summaries, reminders, and wellness tips based on the information you provide and provide relevant content or alerts.
• Sharing data with your doctor. With your consent, we make your submitted information (like images and symptom updates) available to your designated provider and their staff (such as technicians or assistants) for review during virtual or follow-up visits, to support your care.
• Improving the Service. We analyze anonymized or aggregated data to understand what features are most helpful and improve the design, content, and functionality of our Service.
• LLM-based insights. We may use your consumer health data as well as de-identified data with third party large language models (LLMs) to generate helpful summaries, wellness recommendations, or user insights.
• Legal compliance and safety. We use data to meet legal obligations, protect Claren Health, our Service and its users, and detect unauthorized or harmful activity.
• With your consent. If you choose to share your data for a different purpose, we will explain how it will be used at that time.

4. When We Disclose Consumer Health Data

We may disclose your consumer health data in the following limited circumstances:

• With service providers that help us operate and provide the Services (e.g., hosting, analytics, secure storage, AI technology providers, customer care management), who process consumer health data on our behalf and in accordance with our instructions.
• With your healthcare providers and their staff, if you choose to share your information with them.
• With legal or regulatory authorities when required to comply with the law or protect rights, safety, or integrity.
• In connection with a business transfer, such as a merger, financing, acquisition, sale of assets, or bankruptcy transaction or proceeding, in which case we may disclose your consumer health data to the prospective buyer or seller of such business or assets, as well as their and/or our business and legal advisors.
• With others, but only if you direct us to or provide your explicit consent.

We do not sell your consumer health data.

5. Data Retention

We retain consumer health data for as long as is reasonably necessary and proportionate for the purposes described in this Consumer Health Data Privacy Notice, while we have a legitimate business need to do so, or as required by applicable law, whichever is longer. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data and whether we can achieve those purposes through other means, and applicable legal requirements.

6. Your Rights and How to Exercise Them

In addition to the rights described in the general Privacy Policy, depending on where you live, you may have the following rights with respect to your consumer health data:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and access your consumer health data.
• Delete your consumer health data.
• Withdraw your consent from our collection or sharing of your consumer health data.

How to submit a request

Please email us at support@clarenhealth.com. You will not be discriminated against for exercising your rights.

Appealing a denied request

If we deny your request, you can appeal by contacting us at support@clarenhealth.com. If your appeal is unsuccessful, you may file a complaint with your state’s Attorney General. For Washington residents, visit www.atg.wa.gov/file-complaint.

7. Changes to This Notice

We may update this Consumer Health Data Privacy Notice from time to time. The most current version will be available within the Service and on our website. If we make material changes to how we treat your consumer health data, we will notify you through the Service, by email, or through another appropriate method. Updates will take effect once posted, unless otherwise stated.