Consumer Health Data Privacy Policy
1. Who this applies to
This policy describes how Reputable Labs Inc., doing business as Reputable Health ("Reputable", "we"), collects, uses, shares and protects "consumer health data" as defined by the Washington My Health My Data Act, Nevada Senate Bill 370, Connecticut's data privacy act and similar laws. It supplements our Privacy Policy. Your legal rights depend on the law of your state. As a matter of policy, we will also honour the access, deletion and consent-withdrawal requests described in Section 8 from any US account holder, subject to the same exceptions.
2. Consumer health data we collect
- Health conditions, symptoms, diagnoses, medications and supplements you report during screening, in surveys or in your profile.
- Bodily function, vital sign and measurement data from wearables and health apps (for example heart rate, heart rate variability, sleep, temperature, blood oxygen, activity, weight, blood pressure, glucose).
- Biological sample results and biomarkers, including blood, saliva and urine tests, and, in some Studies, epigenetic or other molecular measurements.
- Reproductive or sexual health information where relevant to a Study (for example menstrual cycle or menopause symptoms, pregnancy status).
- Photos and images that reveal health or skin conditions, where a Study requires them.
- Cognitive assessment scores and mental or emotional wellbeing measures (for example mood, stress or sleep quality scales).
- Information that identifies you as seeking health-related services, including your participation in a health Study.
- Facial geometry that our identity-verification provider creates and holds for us when it compares your selfie with your photo ID, and, in skin studies, facial feature measurements from AI skin analysis of your Study photos (held by those providers on our behalf and destroyed under our Biometric Data Retention and Destruction Policy).
- Inferences about your health drawn from any of the above.
3. Sources
Directly from you; from wearables and apps you connect; from laboratories and assessment providers that analyse your samples, scans and tests; from our identity-verification and skin-analysis providers; from contact details you enter in sign-up forms on advertising platforms (these forms do not ask health questions); and from Study activities.
4. Purposes
We collect and use consumer health data to: create and manage your account; determine your eligibility for Studies; run Studies you join (including safety monitoring and adverse-event reporting); show you your data and general wellness insights; pay compensation; prevent fraud and protect research integrity; comply with law; and create de-identified or aggregated data to improve the Platform and publish aggregate research findings. We do not currently license or sell de-identified data; if we ever propose to, we will ask for your separate consent first.
5. Consent
We collect consumer health data only with your consent, given separately from your acceptance of our Terms of Service, or to the extent necessary to provide a service you have requested. We ask for separate consent before sharing consumer health data with any third party other than our processors (service providers acting on our instructions). Studies are conducted under ethics committee oversight and Good Clinical Practice; even where Study data is exempt from these laws, we still share it with Sponsors only with the consent you give in the Study's Consent Form.
Sale. We do not sell consumer health data, with one exception you control: if you sign an optional Photo and Likeness Release, the photos, quotes or recordings you select are disclosed to the Sponsor named in it. That release contains the signed authorization the law requires for a sale, and you may revoke it at any time.
6. Who we share it with
| Recipient | Categories of consumer health data | When |
|---|---|---|
| Processors (identity verification, health data integration, laboratories and assessment providers, skin analysis, surveys, AI insights, messaging and support, orders and rewards, app monitoring, website analytics, hosting; the current companies are listed on our Service Providers and Domains page) | Any category needed to provide their service | To provide the Platform and Studies |
| Study Sponsors (third parties) | Study data labelled with a study code; photos and quotes you release with a signed Photo and Likeness Release | Only with your consent in the Study Consent Form or release. Screening answers are never shared with a Sponsor before you sign the Consent Form |
| Ethics committees, monitors, auditors and regulators | Study records | As required by law or the Consent Form |
| Third-party services you connect or direct us to share with | As you direct | With your consent |
| Successor in a merger or acquisition | All categories | Subject to the consents you gave |
Affiliates. Reputable does not currently share consumer health data with affiliates.
7. What we do not do
- We do not sell consumer health data, other than photos, quotes or recordings you release under a signed Photo and Likeness Release.
- We do not use consumer health data for targeted advertising. We do not place advertising pixels or website visitor identification on any website page that names a health condition, Study or screening question, and we do not send health information from the participant app to advertising companies. If you give permission, our app reports only that it was installed and opened, so we can measure which ads work.
- We do not implement a geofence around any healthcare facility to identify or track people or to send them notifications, messages or advertisements.
- We do not share de-identified data with anyone who has not contractually committed not to re-identify it.
8. Your rights
You have the right to:
- confirm whether we collect, share or sell your consumer health data, and access that data, including a list of all third parties and affiliates with which we have shared it and an active email address or other online mechanism to contact them;
- withdraw consent to our collection and sharing of your consumer health data;
- have your consumer health data deleted (we will also tell our processors and every third party with which we shared it to delete it, subject to the exceptions the law allows, such as data we must keep for safety reporting or research regulations); and
- not be discriminated against for exercising these rights.
9. How to exercise your rights
Use the privacy settings in your account, or email legal@reputable.health with "Consumer Health Data Request" in the subject line. We will verify your identity using information associated with your account and respond within 45 days (extendable once by 45 days where reasonably necessary, with notice).
Appeals. If we decline your request, you may appeal within a reasonable time by replying to our decision or emailing legal@reputable.health with "Appeal" in the subject line. We will respond within 45 days and explain our reasons. If your appeal is denied, you may contact the Attorney General of your state (Washington: www.atg.wa.gov/file-complaint).
10. Security and access
We restrict access to consumer health data to employees, contractors and processors who need it, and protect it with safeguards described in our Privacy Policy.
11. Contact
Reputable Labs Inc., attention Privacy, 251 Little Falls Drive, Wilmington, DE 19808, USA. legal@reputable.health.