Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how PACT AI, Inc. (“PACT AI”, “Company”, “we”, “us”, or “our”) processes “Consumer Health Data,” as that term is defined under applicable state privacy law, about consumers who reside in the states of Nevada, Washington, and any other applicable U.S. jurisdiction who visit the Platform or access the Services, as defined in our Privacy Policy. Please carefully read this Health Data Policy as it contains important information concerning your Consumer Health Data and how we use it.

This Health Data Policy relates only to Consumer Health Data. It does not describe how we process your personal data. For more information about our information practices with respect to personal data, please refer to our Privacy Policy.

 

Categories. We may collect some or all of the following categories of Consumer Health Data based on what you provide to us through your electronic health record (“EHR”) or otherwise share with us:

·       Individual health conditions, treatment, diseases, or diagnoses, including information about your genetic data;

·       Social, psychological, behavioral, and medical interventions;

·       Information that could identify your attempt to seek health care or clinical trial services;

·       Health-related surgeries or procedures;

·       Use or purchase of prescribed medication;

·       Diagnoses or diagnostic testing, treatment, or medication;

·       Gender-affirming care information;

·       Reproductive or sexual health information;

·       Bodily functions, vital signs, symptoms, or measurements;

·       Biometric data;

·       Genetic data;

·       Any inferences of the above categories of consumer health data derived or extrapolated from non-health information; and

·       Any other category of health data that may appear in your EHR.

 

Sources of Collection. We collect Consumer Health Data from the following categories of sources:

·       Directly from you when you share it with us and from your interactions with our Services and

·       From health information exchanges.

 

Purposes of Collection. We collect, processes, and disclose Consumer Health Data for the following business purposes:

  • To provide, operate, maintain, and protect our Platform;

  • To analyze and improve our Platform, including developing new products or services;

  • To communicate with you, respond to your inquiries, and to send you information by email, postal mail, telephone, text message, notifications, or other means about our products and services;

  • To promote and conduct educational, promotional, and marketing events, including those that may be in person (please note that we will obtain your appropriate consent as required under applicable law for advertising activity);

  • To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences across our Platforms;

  • To protect the security or integrity of the Platform, including to perform security analyses to verify that the Platform is working properly and have not been compromised based on our legitimate interests;

  • To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, monitor and enforce compliance with our contracts, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable;

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our customers is among the assets transferred; and

 

·       Any other purpose with your consent.

 

Disclosures. We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:

·       As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law;

·       With your permission, to researchers, research organizations, and their service providers so that you may learn more about potential clinical trial opportunities; and

·       To our service providers, such as auditing and accounting firms, professional services consultants, providers of data hosting, storage, and analytics services, and IT and security vendors.

 

Your Privacy Rights

Depending on your place of residency, you may have the right to submit some or all of the following requests regarding your Consumer Health Data, subject to applicable law and certain exceptions:

Right to confirm and access your Consumer Health Data, including a list of all third parties and affiliates with whom we have shared the Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.

Right to correct your Consumer Health Data. If your Consumer Health Data we maintain is inaccurate and you would like us to rectify it, you may request that we make changes to it.

Right to withdraw consent from collection or sharing of your Consumer Health Data at any time.

Right to delete your Consumer Health Data.

Right to appeal a decision by us regarding your request to exercise any of the above rights.

Please note we do not “sell” your Consumer Health Data or collect Consumer Health Data over time and across different internet websites.

 

Policy Updates

This Health Data Policy may be updated periodically to reflect changes in our privacy practices.  We will post changes on this page and identify the date the policy was last updated.  If you have provided an email address, you also may be notified by email at the last email address you provided us. Alternatively or in conjunction with email notice, we may post notice of such changes on the Platform, or by other means, and/or seek your consent as required, consistent with applicable law.  It is your responsibility to review the Health Data Policy from time to time to view any such changes.  IF YOU DO NOT ACCEPT AND AGREE TO THIS Health Data Policy, INCLUDING ANY CHANGES, THEN YOU MAY NOT ACCESS OR USE THE SERVICES.

 

Contact
For questions about our Health Data Policy or to submit a request concerning your Consumer Health Data, you can contact us by email, at skye@pact-ai.com. Please note that we may take steps to verify your identity before we fulfill your request in accordance with applicable law.

 

Effective date of the Health Data Policy: April 18, 2025