Purpose and Scope
This Consumer Health Data Privacy Policy describes how Fine Wines Health, Inc. ("Fine Wines Health," "we," "us," or "our") collects, uses, shares, and protects "consumer health data" under the Washington My Health My Data Act (MHMDA), the Nevada Consumer Health Data Privacy Law (SB 370), the Connecticut Data Privacy Act as amended, and comparable laws of other states. This policy supplements our Privacy Policy and applies to information we collect that can reasonably identify a consumer's past, present, or future physical or mental health.
Where information we collect is subject to the Health Insurance Portability and Accountability Act (HIPAA), our HIPAA Notice of Privacy Practices controls that information. This policy governs consumer health data that falls outside HIPAA, including data collected through our website, membership community, wellness content, and non-clinical product sales.
Categories of Consumer Health Data We Collect
- Information about menopausal, perimenopausal, and midlife health status, symptoms, and experiences that you submit in questionnaires, community posts, or direct messages.
- Information about reproductive and sexual health that you provide when using our Services.
- Information related to supplement use, sleep, mood, and general wellness inputs.
- Biometric information to the extent you choose to share it, such as height, weight, and lab values you upload for context.
- Precise location information only where you explicitly provide it, for example, when selecting a shipping address or a local clinician.
- Inferences drawn from the above categories, such as topics or product categories likely to be relevant to you.
Sources of Consumer Health Data
We collect consumer health data from: (a) you, when you submit forms, messages, or account information; (b) your clinician, where you direct us to receive clinical summaries; (c) laboratories and diagnostic partners, with your consent; and (d) service providers that help us deliver the Services under contractual confidentiality obligations.
Purposes of Collection and Use
- To provide, maintain, and personalize the Services you request.
- To connect you with licensed clinicians and route prescriptions to licensed pharmacies.
- To fulfill product orders, memberships, and billing.
- To offer educational resources and, where you have opted in, marketing communications about topics relevant to your expressed interests.
- To detect and prevent fraud, abuse, and security incidents.
- To comply with legal obligations and defend our legal rights.
We do not use consumer health data to train third-party artificial intelligence models, and we do not permit third parties to use consumer health data for their own marketing without your affirmative consent.
Sharing of Consumer Health Data
We share consumer health data only with the following categories of recipients, and only to the extent reasonably necessary for the purposes above:
- Licensed clinicians and pharmacies participating in your care.
- Laboratories processing tests you have consented to.
- Technology service providers that host our platform, deliver messages, process payments, or provide customer support under written contracts limiting their use of the information.
- Legal and safety recipients where required by law or to protect against serious harm.
- A successor entity in the event of a merger, acquisition, or similar corporate transaction, subject to this policy.
We do not sell consumer health data. We do not disclose consumer health data for cross-context behavioral advertising.
Your Rights
You may at any time:
- Confirm whether we are collecting, sharing, or selling your consumer health data.
- Access a list of categories of consumer health data we have collected, the sources, the categories of recipients, and the purposes for collection.
- Withdraw consent to the collection and sharing of consumer health data.
- Delete consumer health data, subject to legal and clinical retention exceptions.
- Appeal any adverse decision regarding these rights.
To exercise any right, email privacy@finewineshealth.com or use our data rights request form linked from our Privacy Policy. We will respond within the timeframes required by applicable law, generally forty-five days, and will authenticate your identity before acting on the request. If we decline a request, we will explain the reasons and the appeals process.
Affirmative Consent and Geofencing
We obtain separate affirmative consent before collecting consumer health data for purposes beyond providing Services you have requested. We do not operate geofences around healthcare facilities to identify, track, collect data from, or send notifications to consumers based on their proximity to such facilities.
Retention
We retain consumer health data only as long as reasonably necessary for the purposes described above or as required by law. We review retention periods annually and delete or de-identify data that is no longer needed.
Security
We maintain administrative, technical, and physical safeguards designed to protect consumer health data, including encryption in transit, role-based access controls, audit logging, and vendor security reviews. We require service providers that process consumer health data on our behalf to maintain comparable safeguards.
Contact and Complaints
To contact our privacy team: privacy@finewineshealth.com. For legal inquiries: legal@finewineshealth.com. Washington consumers may also submit complaints to the Washington State Office of the Attorney General.
