Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy provides information regarding how Valar Labs (“we,” “our,” or “us”) processes “consumer health data” as defined by Washington’s My Health My Data Act (“WMHMDA”) and other applicable consumer health privacy laws. In the event of a conflict between Valar Labs’ Privacy Policy and this Consumer Health Data Privacy Policy, this Consumer Health Data Privacy Policy will control with respect to the processing of consumer health data subject to these laws.

Consumer health data we collect

We collect consumer health data in connection with certain of our products and services, such as when you visit our websites or contact us about our offerings (collectively, the “Services”). The type of consumer health data depends on the Service and your interactions with us. Examples of consumer health data that we collect may include:

• information about your health-related conditions, symptoms, status, diagnoses, testing, treatments, or medications;
• information about social, psychological, behavioral, and medical interventions;
• information about your health-related surgeries or procedures;
• biometric data, such as photographs and diagnostic slides;
• precise location information or website activities that could reasonably indicate your attempt to acquire or receive health services or supplies;
• information that could identify you seeking health care services, such as lab results, medical charts, test requisitions, insurance data; and
• other information that may be used to infer or derive data related to the above or other health information.

How we use consumer health data

We primarily collect and use consumer health data as necessary to provide you with products or services that you request or that you or your treating physician, on behalf of you, request or for other purposes for which we obtain your consent as required by applicable law. This may include the following:

• providing you with the Services;
• coordinating with healthcare facilities to obtain necessary patient information or samples to perform diagnostic testing and provide requested services;
• communicating with insurance providers to facilitate billing, secure payments, and verify coverage for the Services;
• communicating with you and providing support, such as to provide you information about the Services, address your inquiries and feedback, requests, and other communications you send us, and provide you with customer support services;
• operating, evaluating, and improving our business, such as to perform accounting, auditing, record keeping, and other internal functions, conducting research, developing new products and services, analyzing and improving our Services, and personalizing your experience;
• complying with law, such as to comply with legal obligations and process and contractual obligations, as well as our policies and terms and conditions; and 
• any other lawful purpose for which we obtain your consent.

We may also collect and use consumer health data as necessary to protect the rights and safety of us, our affiliates, you, or others, such as to:

• prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable state law or federal law; 
• preserve the integrity or security of our systems; and
• investigate, report, or prosecute those responsible for any such action that is illegal under applicable state or federal law.

We may de-identify consumer health data so that it cannot reasonably be reidentified by us or by another person, and we may use this deidentified data for any reason permitted by applicable law. If we de-identify information that was originally based on consumer health data, we maintain and use that information in de-identified form and will not attempt to re-identify the data, except as otherwise permitted under applicable law.

Sources of consumer health data

We collect consumer health data: 

• directly from you, such as when you use the Services or contact us; 
• automatically as you interact with our online Services;
• from your treating physician, who may place test orders or request services on your behalf;
• from our affiliates, business partners, or service providers; and
• from authorized third-party sources.

The specific sources of consumer health data depend on the Service and your interaction with us. 

How we share consumer health data

We may share each of the categories of consumer health data described in this Consumer Health Data Privacy Policy as necessary to provide you with a product or service you request, with your consent, or for certain security-related purposes, as described above. We may also share consumer health data:

• to comply with law or cooperate with lawful requests: We may share your consumer health data with law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation. We may share consumer health as we deem reasonably necessary to support lawful investigations or otherwise to protect our rights or the rights of you or any other party.  
• in the context of a business transfer: We may share your consumer health data with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business;
• for research purposes and to further improve and develop our products: With appropriate consent or as permitted by law, we may share de-identified or aggregated consumer health data with research institutions, academic partners, or other entities conducting research to advance healthcare, diagnostics, or treatments related to our services, as well as to improve and develop our products and technologies.

Third parties and affiliates with which we share consumer health data

As necessary for the purposes described above, we share consumer health data with the following categories of third parties and affiliates:

• Valar Labs affiliates listed include:some text
  • Clinical laboratories;
  • Web hosting and cloud storage services and other IT services providers;
  • Research partners 
• our agents, service providers, suppliers, and other business partners; 
• parties to a business transfer;
• third parties such as government agencies and law enforcement in response to valid legal process or other third parties as necessary to protect us, our affiliates, you, or others; and
• other third parties as necessary to provide the services or products you requested or with your consent. 

How to exercise your rights

Under the WMHMDA, subject to certain exceptions, you may have the right to access or delete consumer health data about you, or receive a list of third parties and affiliates with whom your consumer health data was shared.  You also may have the right, subject to certain exceptions, to withdraw consent relating to the use and sharing of your consumer health data. To exercise these rights, you may contact us at support@valarlabs.com. We will use information you provide in your request to verify your identity, and we may request additional information if necessary to complete the verification process.

If your request to exercise a right under the WMHMDA is denied, you may appeal that decision by contacting us as described below. If your appeal is unsuccessful, you can lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

If you have questions about this Consumer Health Data Privacy Policy or would like to make a complaint to Valar Labs, you can contact us at: 

Valar Labs

200 California Ave Suite 200

Palo Alto

CA 94306

support@valarlabs.com

Supplement to Consumer Health Data Privacy Policy for Nevada consumers

This supplement applies only with respect to Nevada consumers and provides additional disclosures required by Nevada’s consumer health privacy law. 

Requesting Changes to Consumer Health Data. You may request a change to your consumer health data by contacting us at support@valarlabs.com. We will use information you provide in your request to verify your identity, and we may request additional information if necessary to complete the verification process. 

Third Party Collection of Consumer Health Data. Third parties do not collect consumer health data over time and across different websites or online services when you use our online Services. 

Changes to this Consumer Health Data Privacy Policy. We may modify or update this Consumer Health Data Privacy Policy from time to time. We encourage you to visit this Consumer Health Data Privacy Policy regularly to learn about any changes to the way we collect, use, or share your consumer health data. If we make a material change to this Consumer Health Data Privacy Policy, we will take reasonable steps to notify you as required by applicable law.

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