Consumer Health Data Privacy Policy

Effective: February 1, 2026 Last updated: February 1, 2026

1. Introduction

HealthMarkers.ai Inc. ("HealthMarkers," "we," "us," or "our") is committed to protecting the privacy and security of your consumer health data. This Consumer Health Data Privacy Policy ("Policy") supplements our general Privacy Policy and provides additional information about how we collect, use, share, and protect consumer health data as defined under applicable state consumer health data privacy laws, including the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, and similar legislation enacted in other states.

This Policy applies to consumer health data that is collected, processed, or shared by HealthMarkers.ai through our platform, website, mobile applications, and related services.

2. What Is Consumer Health Data?

Consumer health data means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. For purposes of this Policy, consumer health data includes but is not limited to:

Individual health conditions, diagnoses, diseases, or health status
Laboratory test results and biomarker data
Biological age analysis and health scoring metrics
Nutrition, exercise, supplement, and lifestyle data and recommendations
Social, psychological, behavioral, and medical interventions
Health-related surgeries or procedures
Use or purchase of prescribed medications or supplements
Biometric data, including data from wearable device integrations
Genetic data (where applicable through add-on testing services)
Reproductive or sexual health information
Gender-affirming care information
Information identifying a consumer seeking healthcare services
Precise location data that could reasonably indicate a consumer's attempt to acquire or receive health services or supplies

Consumer health data does not include data that is de-identified in accordance with applicable law, publicly available information, or information already protected under the Health Insurance Portability and Accountability Act (HIPAA) where HealthMarkers.ai is acting as a Business Associate under a BAA.

3. Consumer Health Data We Collect

We collect the following categories of consumer health data:

Category	Examples	Source
Laboratory Data	Blood test results, biomarker values, lab panel data	Lab partners (Quest, LabCorp, BioReference), physician uploads, patient uploads
Health Profile Data	Age, sex, height, weight, medical history, family health history, current medications	Patient-provided, physician-provided
AI-Generated Insights	Health analysis, lifestyle recommendations, action plans, biological age calculations	Generated by HealthMarkers.ai AI systems based on lab and profile data
Wearable & Device Data	Sleep metrics, heart rate, activity data, steps, HRV	Oura, Apple Health, Garmin, Fitbit, Peloton, Withings (via user-authorized integrations)
Lifestyle & Behavioral Data	Nutrition habits, exercise routines, supplement use, sleep patterns	Patient-provided through platform interactions

4. How We Use Consumer Health Data

We use consumer health data for the following purposes:

Providing our Services: Processing laboratory results, generating AI-powered health insights, creating personalized lifestyle recommendations, calculating biological age, and delivering interactive patient dashboards — all as drafts for physician review and approval
Longitudinal Health Tracking: Storing historical lab results and health data to enable trend analysis and progress monitoring over time
Wearable Data Integration: Combining wearable device metrics with laboratory data to provide a more comprehensive health picture
Platform Improvement: Improving the accuracy and quality of our AI models and recommendation systems using de-identified, aggregated data
Population Health Reporting: Generating de-identified, aggregated health reports for physician practices (no individual patient data is shared in these reports)
Communication: Sending retest reminders, health updates, and platform notifications based on your health data and testing schedule
Compliance: Meeting legal obligations, responding to lawful requests, and protecting the security and integrity of our platform

5. How We Share Consumer Health Data

We share consumer health data only in the following circumstances:

With Your Physician: Your health data, lab results, and AI-generated insights are shared with the physician practice through which you access HealthMarkers.ai. This is the core function of our platform — enabling your doctor to review, approve, and deliver personalized health guidance.
With Laboratory Partners: We share necessary information with our laboratory partners (Quest Diagnostics, LabCorp, BioReference) to facilitate ordering and processing of lab tests on your behalf.
With Service Providers: We work with carefully selected third-party service providers who assist with data hosting, platform infrastructure, analytics, and customer support. All service providers are bound by data processing agreements and are prohibited from using your data for any purpose other than providing services to HealthMarkers.ai.
With Your Consent: We may share your data with additional parties if you provide explicit, informed consent — for example, if you choose to share your results with another healthcare provider or family member.
For Legal Compliance: We may disclose data when required by law, regulation, legal process, or governmental request.

HealthMarkers.ai does not sell consumer health data. We do not share consumer health data with advertisers, data brokers, or any third parties for marketing purposes.

6. Your Rights

Depending on your state of residence, you may have the following rights regarding your consumer health data:

Right to Know: You may request confirmation of whether we are collecting, sharing, or selling your consumer health data, and obtain a list of all third parties and affiliates with whom we have shared your data during the prior 12 months.
Right to Access: You may request access to your consumer health data that we have collected, including the specific data points and categories of data.
Right to Delete: You may request deletion of your consumer health data. Upon receiving a verified request, we will delete your data and direct any processors or third parties to do the same, subject to certain exceptions permitted by law.
Right to Withdraw Consent: Where we process consumer health data based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise any of these rights, please contact us at privacy@healthmarkers.ai. We will respond to verified requests within the timeframes required by applicable law (typically 30–45 days).

7. Data Security

We implement and maintain reasonable administrative, technical, and physical security measures to protect consumer health data, including:

Encryption of data at rest and in transit (AES-256 and TLS 1.2+)
Access controls limiting data access to authorized personnel on a need-to-know basis
Regular security assessments and penetration testing
Employee training on data handling and privacy best practices
Incident response procedures for potential data breaches
Business Associate Agreements with all covered entities and partners handling protected health information

8. Data Retention

We retain consumer health data for as long as necessary to provide our services, comply with legal obligations, and fulfill the purposes described in this Policy. Longitudinal health tracking data is retained to enable trend analysis over time — a core feature of our platform. Upon account termination, you may request export and deletion of your data. Data will be deleted within 30 days of a verified deletion request, except where retention is required by applicable law.

9. Geofencing

HealthMarkers.ai does not use geofencing technology around healthcare facilities, mental health facilities, reproductive health clinics, or any other physical health-related locations for the purpose of collecting consumer health data, identifying consumers, or sending notifications, messages, or advertisements based on proximity to such facilities.

10. Children's Data

HealthMarkers.ai does not knowingly collect consumer health data from individuals under the age of 18. Our services are intended for adults. If we learn that we have inadvertently collected consumer health data from a minor, we will take immediate steps to delete such data.

11. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, applicable laws, or for other operational, legal, or regulatory reasons. We will provide notice of material changes by updating the "Last updated" date at the top of this Policy and, where required by law, through direct notification. We encourage you to review this Policy periodically.

12. Contact Us

If you have questions about this Consumer Health Data Privacy Policy, wish to exercise your rights, or have concerns about how your health data is being handled, please contact us:

HealthMarkers.ai Inc.
Email: privacy@healthmarkers.ai
Web: healthmarkers.ai/contact

HealthMarkers.ai’s membership includes technology and service fees charged by HealthMarkers.ai, as well as access to prepaid laboratory services provided by independent third parties, and paid to such third parties on your behalf. Laboratory services are provided through leading nationwide partners including Quest Diagnostics, LabCorp, and BioReference Labs at 2,000+ locations. These laboratory service providers are independent third parties that set their own pricing. Certain states may have different rules around lab test billing and administration, which may result in additional fees at the time of laboratory visits. Itemization of all fees is available upon request. Certain add-on tests and services require additional payment not included in standard membership or practice subscription pricing.

HealthMarkers.ai is a healthcare technology company and not a laboratory, medical provider, or clinical practice. All laboratory and medical services are provided by independent third parties. Although HealthMarkers.ai may facilitate access to certain laboratory and medical service providers on your behalf, HealthMarkers.ai does not recommend or refer you to any healthcare providers, and you are free to choose any healthcare provider and to continue using HealthMarkers.ai’s services. HealthMarkers.ai does not offer medical advice, laboratory services, a diagnosis, medical treatment, or any form of medical opinion through our platform or otherwise. All AI-generated insights and lifestyle recommendations are produced as drafts for physician review — no content is visible to patients until a licensed physician has reviewed and approved it. HealthMarkers.ai’s services are not a substitute for medical care, medical advice, and/or a detailed discussion with your primary care physician or other licensed provider. If you have any questions regarding any laboratory results or other information that you access through HealthMarkers.ai, we recommend that you discuss those questions with your physician or other licensed provider. All material, information, data, and content that HealthMarkers.ai provides is strictly for general information purposes.

HealthMarkers.ai does not provide tax, legal, or financial advice. Please be aware that HSA/FSA eligibility, contribution amounts, rollover provisions, and other key features may change annually and differ between plans. We recommend consulting your plan administrator, HR department, or a qualified tax or financial advisor to understand how these accounts apply to your specific situation. We are not responsible for any errors or changes in regulations that may affect your FSA or HSA benefits.

By providing your phone number or email address, you agree to receive communications from HealthMarkers.ai. Message and data rates may apply. Message frequency varies.

For other important information regarding the services provided by HealthMarkers.ai, please see our terms of service, privacy policy, and consumer health data privacy policy.

Better health starts with better data.

HealthMarkers.ai membership includes technology and service fees charged by HealthMarkers.ai Inc., as well as access to AI-powered health analysis and, where applicable, prepaid laboratory services provided by independent third parties and paid to such third parties on your behalf. Laboratory services are available through leading nationwide providers at 2,000+ locations. Certain states may have different rules around lab test billing and administration, and additional fees may apply at the time of laboratory visits. Itemization of all fees is available upon request. Certain add-on tests and services require additional payment not included in standard membership pricing.

HealthMarkers.ai is a healthcare technology company and not a laboratory, medical provider, or clinical practice. All laboratory and medical services are provided by independent third parties, including Quest Diagnostics, LabCorp, and BioReference Laboratories. These laboratory and medical service providers set their own pricing. Although HealthMarkers.ai may facilitate easy access to certain laboratory and medical service providers on your behalf, HealthMarkers.ai does not recommend or refer you to any healthcare providers, and you are free to choose any healthcare provider and to continue to use HealthMarkers.ai's services.

HealthMarkers.ai does not offer medical advice, laboratory services, a diagnosis, medical treatment, or any form of medical opinion, through our services or otherwise. All AI-generated insights and lifestyle recommendations are produced as drafts for physician review — no content is delivered to patients until a licensed physician has reviewed, edited, and approved it. HealthMarkers.ai's services are not a substitute for medical care, medical advice, and/or a detailed discussion with your primary care physician or other licensed provider. If you have any questions regarding any laboratory results or other information that you access through HealthMarkers.ai, we recommend that you discuss those questions with your physician or another licensed provider. All material, information, data, and content that HealthMarkers.ai provides is strictly for general information purposes. For other important information regarding our services, please see our terms of service.

By providing your email address or phone number, you agree to receive communications from HealthMarkers.ai. Message and data rates may apply. Message frequency varies. You may opt out at any time.

For information about how we handle consumer health data, including data collected under state consumer health data privacy laws, please see our Consumer Health Data Privacy Policy.

Better health starts with better data.