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Consumer Health Data Notice

US CHD Laws, Data Collection, Use & Your Rights

Last Updated on August 17, 2023

Scope

This notice supplements our Privacy Policy and applies to information that is regulated as "consumer health data" (CHD) under certain U.S. state laws (for example Washington's My Health My Data Act and Nevada SB 370). Where those laws require stricter duties, this notice controls for CHD.

1

Definitions & Relationship to HIPAA

Consumer Health Data (CHD). CHD generally means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status, health-related inference, or efforts to seek health services. Examples appear below.

We are not a HIPAA covered entity. ClinicBooking is a platform that helps consumers discover and contact independent providers. We are not a covered entity under HIPAA, and we are not a business associate unless we separately sign a Business Associate Agreement (BAA) with a provider. We instruct users and providers not to upload Protected Health Information (PHI) to our platform outside secure, intended fields. If PHI is inadvertently received, we minimize access and delete it promptly consistent with law and our retention rules.

2

Categories of Consumer Health Data

  • Self-submitted health details in reviews, questions, messages, or forms (e.g., symptoms, conditions, desired treatments, recovery experiences).
  • Intent signals showing you sought health information or services (e.g., searching for a specific procedure, viewing a provider page, sending an inquiry).
  • Derived health inferences that may be associated with your activity (e.g., interest in a treatment category).
  • Location information related to finding care (e.g., city/ZIP you enter to locate a clinic).
  • Research & service feedback you provide in surveys about conditions, outcomes, or product experience.
3

CHD Matrix: Sources, Purposes, Sharing, Retention

"Share" below refers to disclosures to third parties; "processors" act on our instructions. We do not sell CHD as defined by CHD laws.

Category (CHD)

Self-submitted health details

Examples

Symptoms, conditions, desired procedures, recovery notes

Sources

You (forms, reviews, Q&A, messages)

Primary Purposes

Connect you with providers at your request; support; safety & abuse prevention; legal compliance

Disclosures

To providers you choose; processors (hosting, support, anti-abuse); legal authorities if required

Retention

For the engagement + required legal periods; then delete or de-identify

Category (CHD)

Intent signals

Examples

Clicks on procedure pages; sending an inquiry; favorites

Sources

Automatic (site/app); you

Primary Purposes

Operate core features; improve relevance; measure product performance

Disclosures

Processors for analytics strictly under our instructions; no CHD "sale"

Retention

Short, purpose-limited windows; then aggregate/de-identify

Category (CHD)

Derived inferences

Examples

Association to a category (e.g., "interested in rhinoplasty")

Sources

We derive from your use

Primary Purposes

Personalize onsite experience you request; prevent spam/fraud

Disclosures

Not disclosed for third-party advertising; processors only

Retention

Minimized; deleted when no longer needed or upon request

Category (CHD)

Location (for care search)

Examples

City/ZIP you enter; coarse IP region

Sources

You; automatic

Primary Purposes

Show nearby options; localize contact info

Disclosures

Processors (geolocation & mapping); never used for geofenced ads near health facilities

Retention

Short window; then generalized or deleted

Category (CHD)

Research & feedback

Examples

Survey responses on conditions/treatments

Sources

You

Primary Purposes

Improve services; quality & safety monitoring; aggregate insights

Disclosures

Aggregate outputs may be shared; no disclosure of your identifiable CHD

Retention

Kept only as required to complete the study; then de-identified

4

Consent, Sale/Share, Targeting & Geofencing

  • Collection & Sharing Consent (WA / NV). For Washington and Nevada residents, we obtain opt-in consent before collecting CHD beyond what is necessary to provide a service you request, and before sharing CHD. Separate, time-bound authorization is required to sell CHD; we do not sell CHD.
  • Targeted advertising. We do not use your CHD for third-party targeted advertising. Where law requires honoring browser-level universal opt-out mechanisms (e.g., Global Privacy Control) for "sale" or "targeted advertising," we do so.
  • Geofencing near health facilities. We do not use geofences to identify, track, collect CHD from, or send targeted health-related messages to consumers within the prohibited distance of a healthcare facility (e.g., within 2,000 feet under WA law).
  • Cookies & local storage. Any tags that could collect CHD operate only with appropriate consent and are limited to purposes described here and in our Cookies Policy.
5

Your CHD Rights & How to Exercise Them

Depending on your state, you may have rights to: (i) know whether we collect or share your CHD; (ii) access a list of CHD categories and specific items; (iii) obtain a copy (portable format); (iv) delete CHD; and (v) withdraw consent. Washington also provides a right to confirm processing, and we must delete within a short statutory period once verified.

How to submit a request: Email privacy@clinicbooking.com or use our privacy form (if available on your account). For California opt-outs relating to sale/share of personal information (including health-related signals), use "Do Not Sell or Share My Personal Information" at clinicbooking.com/terms-of-service.

6

Verification, Agents & Appeals

  • Verification. We may verify your request (e.g., email or phone confirmation; signed declaration for deletion). For sensitive requests, we may ask for additional data strictly to verify identity and will delete it after verification.
  • Authorized agents. You may designate an authorized agent. We may require proof of agency (e.g., signed permission or power of attorney) and direct verification.
  • Timelines & appeals. We respond within applicable statutory timelines (e.g., WA generally requires responses within 45 days with a possible extension; deletion within 45 days). If we deny your request, you may appeal by replying to our decision or emailing privacy@clinicbooking.com. If you remain unsatisfied, you may contact your state AG.
7

Security, Retention & Minimization

  • Safeguards. We employ administrative, technical, and physical controls appropriate to the sensitivity of CHD, including encryption in transit and at rest, access controls, logging, least-privilege, vulnerability management, and vendor due diligence.
  • Minimization. We collect only what is reasonably necessary to provide services you request or as permitted by law and retain CHD only as long as needed for those purposes or legal obligations, then delete or de-identify.
  • De-identified data. We may use de-identified or aggregated data for analytics and service improvement; we commit to maintaining de-identification and not attempting re-identification.
8

Minors & Sensitive Locations

  • Children under 13. We do not knowingly collect personal information from children under 13. If we learn we have, we will delete it. Parents/guardians may contact us to request deletion.
  • Teens. For minors where state law requires enhanced consent, we seek consent from the minor or their guardian as applicable and do not use CHD for targeted advertising.
  • Sensitive locations. We do not apply geofenced health-related tracking/ads near healthcare facilities, consistent with state CHD laws.
9

Cross-Border Transfers

We may process data in the United States and other jurisdictions via vetted processors. We use appropriate safeguards for cross-border transfers, and we require processors to follow our instructions and protect CHD to at least this standard.

10

Changes to this Notice

We may update this notice to reflect changes in our practices or the law. Material changes will be posted here with a new "Last updated" date. Where required, we will seek new consent.

11

How to Contact Us

Address

Spyface Tech Company, LLC (d/b/a "ClinicBooking")
30 N Gould St Ste N
Sheridan, WY 82801, USA

12

Legal References (Plain-English)

  • Washington – My Health My Data Act. Requires consent for collecting/sharing CHD, authorizations for sale, specific rights (access/deletion/withdrawal), timelines, and prohibits geofencing within 2,000 feet of healthcare facilities. See legislative analysis summarizing consent, rights, effective dates (general 3/31/2024; small businesses 6/30/2024) and geofencing ban.
  • Nevada – SB 370 (Consumer Health Data Privacy Law). Requires privacy policy disclosures, consumer rights (access, deletion, opt-out of sale), processor contracts, and bans geofencing tied to health facilities. Effective 3/31/2024.
  • Colorado – Privacy Act & Rules. Recognizes universal opt-out mechanisms (e.g., GPC) for sale/targeted advertising and imposes heightened duties for sensitive data. Controllers must honor AG-approved UOOMs (July 2024+).