ShareWell Consumer Health Data Privacy Policy

Effective Date: April 1, 2025

This Consumer Health Data Privacy Policy (the “Consumer Health Data Privacy Policy”) supplements the ShareWell Privacy Policy and explains how ShareWell Labs Co. (“ShareWell,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Consumer Health Data (as defined below) of residents of the state of Washington or Nevada, or individuals whose Consumer Health Data is collected in those states through the www.sharewellnow.com website (the “Site”). In addition, this Consumer Health Data Privacy Policy covers the related content, products, services, or other functionality offered on or through the Site, and any other website or mobile application that we own or control and which posts or links to this Consumer Health Data Privacy Policy (all collectively, the “Services”).

This Consumer Health Data Privacy Policy does not address privacy practices relating to ShareWell job applicants, employees, and other personnel. Please note that this Consumer Health Data Privacy Policy is not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Collection and Use of Consumer Health Data

The term “Consumer Health Data” as used in this Consumer Health Privacy Policy means any personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Washington My Health My Data Act or the Nevada Consumer Health Data Privacy Law (the “Consumer Health Privacy Laws”). The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, is information that you decide to share with us. This includes information collected through consultation questionnaires, your communications with us, or from your other interactions with our Services. Consumer Health Data does not include information that is considered deidentified under the Consumer Health Privacy Laws.

Examples of Consumer Health Data that we may collect include:

• Information you share about your health-related conditions, symptoms, experiences, diagnoses, testing, or treatments.
• Any health-related information that you share with our customer support services.
• Other information that may be used to infer or derive data related to the above or other health-related information.

We may process and/or use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes:

• To manage and provide the Services.
• To manage, provide, maintain, and improve the business.
• To respond to your questions, concerns, and other requests for assistance.
• To customize your experience on the Services.
• To create anonymous, aggregated, or de-identified data.

We may also combine your Consumer Health Data with other personal information we collect directly from you or receive from other sources.

1. Sources of Consumer Health Data

The Consumer Health Data we collect depends on the context of your interactions with our Services and, in most cases, is information that you decide to share with us. For more information, please see the “How we collect your information” section of our Privacy Policy.

2. Our Disclosure of Consumer Health Data

We may share the categories of Consumer Health Data set forth above as follows:

• Service Providers: We work with a variety of service providers who help us process your Consumer Health Data to facilitate the operation of our Sites and Services, to support our communications and to support our advocacy programs.
• Business Transfers: We may take part in or be involved with a business transaction, such as a merger, acquisition or asset sale. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction.
• Other Parties as Required by Law or as Necessary: We may disclose Consumer Health Data to third parties in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.
• Other Users: We make available personal information that you choose to share with other ShareWell users via our Services. Please keep in mind that the users who view user-generated content may reshare or redistribute the content both on and off our Services or save or copy the content outside of our Services.
• With Your Consent: We may disclose Consumer Health Data about you to service providers or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction we may post your review on our Sites or Services-related publications.

3. Your Privacy Rights

The Washington and Nevada consumer health data privacy laws provide the following rights with respect to Consumer Health Data:

• Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
• Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.
• Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.

4. How to Exercise Your Privacy Rights

To exercise any of the privacy rights set forth above or to review [or request changes to] data, please submit a request to support@sharewellnow.com.

Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including, but not limited to, your email address and phone number.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.

5. Appealing Privacy Rights Decisions

If your request to exercise a consumer health data privacy right is denied, you may appeal that decision by contacting us at support@sharewellnow.com. If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable State Attorney General.

6. Changes to this Consumer Health Data Privacy Policy

We may update this Consumer Health Data Privacy Policy from time to time. When we make changes to this Consumer Health Data Privacy Policy, we will notify you by changing the date at the beginning of this Consumer Health Data Privacy Policy. If we make material changes to this Consumer Health Data Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.