Consumer health data privacy policy

This notice sits alongside our privacy policy and covers one specific thing: consumer health data. Washington's My Health My Data Act and Nevada's equivalent law require it to be published on its own, so that is what this page is.

Consumer health data means information that identifies your past, present or future physical or mental health status. For a service like this one it includes the fact that you sought treatment at all.

Reclaim is a telehealth platform. Reclaim itself does not practise medicine and does not dispense medication. Medical care is provided by DrTelx, an independent telehealth medical group whose clinicians are licensed in the states where care is offered. Prescriptions are filled by independent, licensed US pharmacies — EPIQ Scripts, Foothills Professional Pharmacy and Emerald Compounding Pharmacy.

Why this notice exists. Your medical record and your dispensing record are held by the medical group and the pharmacy, who are HIPAA covered entities. Reclaim is not one. The health information Reclaim holds therefore falls outside HIPAA and inside these consumer health data laws. Neither law has a size threshold, so they apply to us regardless of how small we are.

What we collect

• Your assessment answers — your symptoms, what you want to change, your medical and medication history, and your responses to safety questions.
• Information that reveals a health condition by implication — the treatment you were prescribed, the products you order, and the fact that you use this service at all.
• Messages with your clinician, and any photographs you choose to upload.
• Care and fulfilment records — whether a prescription was issued, what was dispensed, and your refill history.

Where it comes from

Mostly from you, through the assessment and your messages. The rest comes back to us from the treating medical group (whether a prescription was issued) and from the dispensing pharmacy (what was filled and when). We do not buy health data about you from anyone, and we do not infer it from your activity on other companies' websites.

Why we collect it

To route your assessment to a licensed clinician; to let that clinician decide whether treatment is appropriate and to prescribe safely; to have a prescription filled and shipped to you; to support you and answer your questions; and to meet the recordkeeping and drug-safety obligations the law places on a service like this. Apart from the Meta pixel and partner-tracking signals described below, we do not use it for advertising, and we do not use it to build a profile of you for any purpose beyond your care.

Who we share it with

These are all the categories of third party and affiliate we share consumer health data with, and how to reach them:

• The treating medical group — DrTelx, an independent telehealth medical group, at drtelx.com. They receive your assessment so a clinician can review it.
• The dispensing pharmacy — EPIQ Scripts, 465 W President George Bush Hwy Suite 240, Richardson, TX 75080, (833) 654-3553; Foothills Professional Pharmacy, 2727 W Baseline Rd Suite 1, Tempe, AZ 85283, (480) 496-4444; or Emerald Compounding Pharmacy, 5325 Primrose Lake Circle Suite A, Tampa, FL 33647, (321) 321-3313. Whichever fills your prescription receives what it needs to dispense it.
• Our telehealth platform provider, which hosts the assessment and your account, and its product-analytics provider. As explained in our privacy policy, the platform's analytics include session recording, which can capture what you enter while completing your assessment.
• Operational service providers — hosting, communications and shipping carriers — each limited by written agreement to performing that service for us.
• Meta Platforms (the company behind Facebook and Instagram), through the Meta pixel described in our privacy policy. It receives the fact that a browser visited this website or clicked through to start a visit and, on the assessment platform, that an assessment was started or completed and that a purchase was made, with the amount, but never the content of your answers. Once you have entered your details in the assessment, your email address, phone number and name are also sent to Meta in hashed (scrambled) form, so that Meta can match the event to an account. Because the fact that you sought care is itself consumer health data, we treat these signals as consumer health data shared with Meta. The opt-out link in our privacy policy, or a Global Privacy Control signal, stops them from this website entirely.
• Everflow, our partner-tracking provider, described in our privacy policy. It records visits to this website, with the partner's codes when a visit arrives through a marketing partner's link, and, if treatment is started, the sale, with its amount and an order reference, so that the right partner, or none, can be credited. It never receives the content of your answers, your name or your contact details. Because the fact that you sought care is itself consumer health data, we treat these records as consumer health data shared with Everflow.
• Legal and safety recipients, where a law or court order requires disclosure, or where disclosure is needed to protect someone's safety.

We do not sell consumer health data, and we have not sold any in the preceding twelve months. A sale would require your separate signed authorisation, and we do not ask for one. We do not use geofencing around any health facility.

Your rights

• To confirm and access — to be told whether we are collecting, sharing or selling your consumer health data, and to get a copy of it.
• To know who has it — to receive a list of every third party and affiliate we have shared it with, with contact details for each.
• To withdraw consent — separately, to our collecting it and to our sharing it.
• To delete — to have us delete it. We will delete our copy and tell our service providers to delete theirs. Where the medical group or a pharmacy must keep a record under a law that binds them, we will tell you which record and why we cannot delete it.
• To be treated the same either way — exercising any of these rights will not change the price you pay or the care you receive.

How to exercise them

Make any of these requests through our contact page, and say which right you are exercising. We will verify your identity first, and we will respond within 45 days. If your request is complex we may take up to 45 days more, and we will tell you within the first 45 days if we need to.

If we refuse a request you may appeal, free of charge, by contacting us again and saying you are appealing. A different person will review it and write to you with the outcome within 45 days. If we refuse the appeal you can complain to the Washington Attorney General at atg.wa.gov, or to the Nevada Attorney General at ag.nv.gov.

Changes

If we change this notice we will update the date at the top of this page, and we will not apply a materially different practice to consumer health data we already hold without asking you first.