Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy explains how HEAL (Help Each Other Achieve Life) (“HEAL”, “we”) collects, uses, shares and protects consumer health data. It’s written to meet Washington’s My Health My Data Act (RCW 19.373), Nevada’s consumer health data law (SB 370, NRS 603A), and Connecticut’s consumer health data provisions in its Data Privacy Act. Similar laws in other states are covered too.

Those laws protect residents of particular states. We apply this policy to every member and visitor, wherever you live. It works alongside our Privacy Policy, which covers all the information HEAL handles. Where the two differ, the more protective one applies to health data.

HEAL is a peer community, not a healthcare provider, so HIPAA doesn’t apply to us. That’s exactly why these state laws, and this policy, matter.

“Consumer health data” means personal information that is linked or reasonably linkable to you and identifies your past, present or future physical or mental health status. That includes information about substance use, treatment and recovery, and information that could reveal that you’re seeking health care. On HEAL, we treat all of the following as consumer health data:

• Recovery status: whether you told us you’re here in recovery, as family or as an ally, and the topics you said interest you.
• Workbook: your answers, which exercises you started or finished and your progress, and the content of any share link.
• Check-ins: your daily mood rating, the practices you ticked and any private note.
• Meetings: your RSVPs, your attendance and presence in live rooms (when you joined and left), the kind of meeting, and your post-meeting feedback.
• Help board: what you ask for or offer (for example a ride, housing or sponsorship), the topics our safety screen flags, and the members involved.
• Provider directory activity: the provider pages you view and the directory searches you make in the apps (we record the length of a search, never its words), because they can show you’re looking for treatment.
• Usage signals that reveal any of the above: app or website events such as “joined a meeting” or “opened crisis lines”, and the city-level places your account was active from.
• Reports and moderation records that mention any of the above.

We don’t draw inferences about your health from other data, and we don’t collect biometric or genetic data or precise location.

The HEAL shop and Supporter plans are optional. We don’t collect shop orders or support payments as consumer health data, and we don’t use them as health data: they aren’t used to identify, infer or track anyone’s health, they aren’t needed for any health-related feature, and they are stored separately from your recovery status, workbook, check-ins, meetings and help-board activity. We never combine them with that information.

To be honest about the limits of that: buying HEAL merch, or supporting HEAL, could suggest a connection to a recovery community, and some product designs carry encouraging recovery phrases. So we give this information the same protections as consumer health data:

• we never sell it, for money or anything else of value, and never use it for advertising or marketing based on recovery;
• we share it only with the processors that take payment and make and ship orders (Stripe and Printful), and with carriers for delivery;
• you can access it and ask us to delete it, as this policy describes, except for the order and payment records tax and accounting law requires us to keep, which we keep minimized and unlinked from your profile;
• supporter status isn’t shown to other members unless you switch on the supporter badge or join the supporters wall.

See the Shop Terms of Sale and Supporter Terms for the purchase and billing terms.

We collect and use consumer health data only as reasonably necessary for these purposes:

• to provide the features you ask for: your workbook and check-ins, meetings and reminders, the help board, share links and a personalized home screen;
• to keep members safe: routing high-risk help requests to a human and showing crisis resources, handling reports and blocks, and letting hosts manage rooms;
• to secure HEAL and prevent fraud and abuse;
• to understand, in aggregate, which features help people, using usage events that never include what you wrote;
• to comply with the law and respond to your requests.

We don’t use consumer health data for advertising, marketing to you, profiling or any purpose you haven’t been told about.

We collect consumer health data only (a) with your consent, or (b) when it’s necessary to provide a feature you’ve asked for. During onboarding, before you add anything about your recovery, we show you this policy and record your agreement, with its version and date. Before your first workbook entry, we show you how your private writing is handled and record your agreement. Meeting room rules are shown and accepted before you join.

Everything beyond your account is optional. You don’t have to say you’re in recovery, use the workbook, check in or post on the help board to be a member.

Withdrawing consent. You can withdraw consent at any time. Clear your recovery status or interests in your profile, delete individual workbook entries, revoke share links, or delete your account to stop all collection. You can also ask us at privacy@teleheal.com. Once you withdraw, we stop collecting that data and delete what we hold, except where the law lets us keep it (see “Your rights”).

Sharing consumer health data needs its own consent, separate from your consent to collection. We share it only in these ways:

• With processors that run HEAL on our behalf, under contracts that limit them to our instructions (listed below). The law doesn’t treat this as “sharing”, but we list them anyway.
• When you direct it. Creating a share link, accepting a help-board offer (which reveals the contact detail you chose), or joining a live room (where others see your display name) is your specific, separate consent to that disclosure, to those people only.
• When the law requires it, as described in our law enforcement guidelines, which explain how we resist requests aimed at recovery information.

If we ever want to share consumer health data in any other way, we will first ask for your separate, express consent. The request will tell you what we’d share, with whom, why, and how to withdraw your consent. Saying no will never affect your access to HEAL.

Categories of recipients: cloud hosting and database providers; email delivery; real-time meeting audio; mobile push relay; network security and bot protection; website and app analytics (which receive no health-revealing app activity); AI providers for the website chat (scrubbed questions only); payment processing and fraud prevention, and print-on-demand production and shipping, for shop orders and support payments only; and the people you choose to share with (share-link recipients, help-board members whose offers you accept, and people in meetings with you).

Affiliates: HEAL has no affiliates that receive consumer health data. If that changes, we’ll name them here first.

Third parties: we don’t provide consumer health data to any third party for its own purposes.

Processors: these companies process data for us, and this is what each can touch:

None of them receives workbook answers or check-in notes in readable form. More detail is on the service providers page.

We don’t set up virtual boundaries around health care facilities, including treatment centers, clinics or pharmacies, to identify, track, message or collect data from people who enter them. The laws we follow ban this within 2,000 feet (Washington) or 1,750 feet (Nevada and Connecticut), and we don’t do it at any distance. We don’t collect GPS or precise location. The only location we hold is a city-level estimate from your IP address, rounded to about 11 km and worked out on our own servers.

• Confirm and access. Ask whether we collect, share or sell your consumer health data (we never sell it), and get a copy of it.
• A list of recipients. Get a list of all third parties and affiliates we’ve shared your consumer health data with, with an active email address or other online contact for each. Today that list is the processors above, plus anyone you shared with yourself.
• Withdraw consent to collection or sharing at any time, as explained above.
• Delete. Have your consumer health data deleted. You can do this yourself by deleting your account, which immediately erases your workbook and check-ins, meeting RSVPs, attendance and feedback, help offers and requests, notifications, blocks, push tokens, app and website usage events linked to you, and your activity and location history, or by asking us. A help request that a report or staff review points at keeps an empty row, with your text and contact removed, so the safety record still makes sense. When we delete, we also tell every processor and anyone we shared it with to delete it. Copies in backups are deleted as the backups roll over (see Your Data Rights & Deletion), and are never restored for any other use in the meantime.
• No retaliation. Using these rights never affects your access to HEAL or how you’re treated.

We may keep a minimal record when the law allows it: for example, to keep a safety report about another member, to meet a legal obligation, or to prevent fraud or abuse. We’ll tell you if this applies to your request.

• In the app: Profile → Your data lets you request an export, a correction or a deletion and track its status. Delete your account from account settings for immediate deletion.
• By email: privacy@teleheal.com, from the address on your account if you have one.

Verifying you. Requests from inside your account need no further proof. For email requests, we confirm you control the account’s email address. We don’t ask for government ID or health details, and we use what you give us only to handle the request. If we can’t verify a request, we’ll tell you why.

Authorized agents. Someone can act for you with your signed permission or a power of attorney. We may also ask you to confirm the request with us directly.

Requests are free. We may charge or decline only if requests are clearly unfounded or excessive, which the law limits (for example, more than twice in 12 months), and we’ll explain why.

• We aim to answer within 30 days, and we always answer within 45 days of receiving your request.
• If it’s reasonably necessary, we may extend once by another 45 days. We’ll tell you within the first 45 days, and explain why.
• We act on a withdrawal of consent, or a request to stop sharing, as soon as practicable, and in any case within the same 45-day window.

If we decline your request, in whole or part, we’ll explain why. To appeal, reply to our answer or email privacy@teleheal.com with “Appeal” in the subject. Someone who wasn’t involved in the first decision will review it and reply in writing within 45 days (60 days where state law allows), explaining what we did and why.

If you disagree with the result, you can contact the Attorney General where you live:

• Washington: Attorney General’s Office, atg.wa.gov
• Nevada: Attorney General’s Office, ag.nv.gov
• Connecticut: Attorney General’s Office, portal.ct.gov/ag

Only staff whose role needs it can access consumer health data. No staff role can read workbook answers or check-in notes, which are sealed with AES-256-GCM using a key held only by our application server. Staff actions are recorded in an audit log. Data is encrypted in transit, and processors are bound by contract to confidentiality and security. Notifications never contain workbook text, check-in notes, mood or who attended a meeting, and emails about meetings and the help board are generic. City-level location history is kept for 90 days and active-day records for 13 months. See the Privacy Policy and our security page for more.

If we change this policy in a way that affects consumer health data, we’ll tell you before the change takes effect. If it would mean collecting new categories, using them for new purposes, or sharing them with new recipients, we’ll ask for your consent first. Questions or requests: privacy@teleheal.com.