Consumer Health Data Privacy Policy

VERSION 1.0 — Last Updated: June 26, 2024

This Consumer Health Data Privacy Policy (“Policy”) provides you with information about how Allora Health, Inc. d/b/a Evvy (“Evvy,” “we,” or “us”) may collect, use, share, or otherwise process your “Consumer Health Data”, as defined in Nevada and Washington Law. This Health Privacy Policy serves as a supplement to our Privacy Policy.

We may update this Policy from time to time. Any updated Policy will be effective when posted. Please check this Policy periodically for updates. If required by law, we will contact you directly to provide you with an updated Policy.

Types of Consumer Health Data We Collect 

The Consumer Health Data that we collect may include: 

• Individual health conditions, treatment, diseases, or diagnosis;
• Social, psychological, behavioral, and medical interventions;
• Health-related surgeries or procedures;
• Use or purchase of prescribed medication;
• Bodily functions, vital signs, symptoms, or measurements of the information described in this section;
• Diagnoses or diagnostic testing, treatment, or medication;
• Gender-affirming care information. 
• Reproductive or sexual health information.
•      Genetic data. Our collection of Genetic Data may include physical samples provided in connection with your use of our Products and Services (such as a vaginal swab).
• Inferences about health derived from other health or non-health data. For example, we may infer health conditions based on portions of our website you visit or purchases or attempted purchases.

Sources of Consumer Health Data

• Data You Provide: When you contact us or make an account on the Service, fill out questionnaires, or provide physical samples.
• Information Automatically Collected. We may collect Consumer Health Data subject to applicable law using automated data collection technologies as described in the "Cookies and Other Tracking Technologies" section in our Privacy Policy.
• From third parties. We may collect Consumer Health Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, financial institutions and payment processors, or other parties who interact with us.
• From publicly available sources.  We may collect Consumer Health Data about you from publicly available sources, such as public profiles and websites.

Use of Consumer Health Data

We may use Consumer Health Data for the following purposes:

• To provide you products and services. For example, we may use Consumer Health Data to make our website, products and services available to you; register, verify, and maintain your account with us; provide and deliver you the goods and services you request; and provide customer service.
• For our internal business purposes. For example, we may use Consumer Health Data to maintain internal business records, such as accounting, document management and similar activities; enforce our policies and rules; management reporting; auditing; and IT security and administration.
• For our internal research and product improvement purposes. For example, we may use Consumer Health Data to measure and improve our products or services; design new products and services; evaluate the effectiveness of our advertising or marketing efforts; and debug and repair errors with our systems, networks, and equipment.
• For research studies. For example, to support scientific discoveries related to women’s health conditions and publish those discoveries​​, Evvy may also remove personal identifiers from Consumer Health Data and maintain it in anonymous and aggregate form that may later be combined with other information to generate anonymized and aggregated statistical information. Evvy may share, publicly or privately, anonymized and aggregated statistical information from the Services. If Evvy shares anonymized and aggregated statistical information, then it will do so in a manner that no specific individual can be identified by its use. Anonymized and aggregated statistical information may be displayed on the Services as part of collaborative learning.
• For legal, safety or security reasons. For example, we may use Consumer Health Data to comply with legal, reporting, and similar requirements; investigate and respond to claims against us; establish, exercise or defend legal claims; protect our, your, and other third parties’ safety, property or rights; detect, prevent, and respond to security incidents and health and safety issues (including managing spread of communicable diseases); and protect against malicious, deceptive, fraudulent, or illegal activity.
• In connection with a business transaction. For example, if we sell or transfer all or a portion of our business or assets. We will inform all impacted parties if this occurs.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

Types of Consumer Health Data We May Share

We may share each of the categories of Consumer Health Data that we collect for the purposes described above.   

Disclosure of Consumer Health Data

We disclose the Consumer Health Data described above to third parties, including the categories of recipients described below:

• 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. 
• 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 and related financial services.
• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes. For example, we may share Consumer Health Data to comply with law or legal requirements, to enforce or apply our Terms of Service and other agreements or policies, and to protect our, our customers’, or third parties' safety, property, or rights.
• Other entities in connection with a corporate transaction. For example, to an acquirer in connection with a sale or transfer all or a portion of our business or assets.
• The public. For example, if you leave comments on our blog posts or reviews on our product pages. Any Consumer Health Data in comments, reviews, or other content that you share in public areas of our online services may be read, collected, or used by other users or the public. 
• Entities to which you have consented to the disclosure.

Your Rights

Washington and Nevada consumers have certain rights regarding their Consumer Health Data, including:

• Right to Access. You have the right to confirm whether we process your Consumer Health Data and to obtain information about how we process that data. ‍
• Right to Delete. You have the right to request that we delete your Consumer Health Data.
• ‍Right to Withdraw Consent. If you provided consent for our processing of your Consumer Health Data, you may have the right to withdraw that consent.
• ‍Right to Change. You have the right to ask that we change the Consumer Health Data that we collect.

To exercise your rights, please contact us at support@evvy.com.

Contact Us

If you have questions regarding this Consumer Health Privacy Notice, please contact us at support@evvy.com.