Consumer Health Data Privacy Policy
Last modified: 03/11/2025
This Consumer Health Data Privacy Policy (this “Policy”) applies to personal information defined as “consumer health data” under US state privacy laws, including Washington’s My Health Data Act and Nevada’s consumer health privacy law.
Please read this Policy carefully to understand our policies and practices regarding your consumer health data and how we will treat it. If you do not agree with our policies and practices, you should not use the sites, products, applications, platforms, or other services linking to this Policy.
Other privacy policies may apply for your personal information that is not consumer health data. To view our privacy notices describing how we treat other personal information, visit our Privacy policy in the footer.
Scope
This Policy describes how Nelson Bach (USA) Ltd (“NBUSA”) collect, use, share and otherwise process consumer health data in connection with our websites, applications, and other online platforms which link to or display this Policy in the United States, or consumer health data we collect via emails or other offline methods (collectively, our “Platform”). This Policy is not, however, a contract and does not create any legal rights or obligations.
Consumer Health Data We May Collect About You
We collect and use different types of consumer health data from and about you, including:
- Data identifying a consumer seeking health care services. Health care services means any service provided to a person to assess, measure, improve, or learn about a person's mental or physical health, including but not limited to:
- individual health conditions, status, diseases, or diagnoses;
- social, psychological, behavioral, and medical interventions;
- health-related surgeries or procedures;
- use or purchase of medication;
- bodily functions, vital signs, symptoms, or measurements of the information described in this subsection;
- diagnoses or diagnostic testing, treatment, or medication;
Any inferences of the above categories derived, extrapolated, or inferred from non-health information.
We use these categories of consumer health data for the following purposes:
- Fulfilling the purposes for which you provided the data or that were described when it was collected.
- Performing the services or providing the goods that you request from us and responding to your questions or requests for information.
- Notifying you about changes to our sites, applications, products, or services.
Facilitating services and operations performance, security, and integrity, including:
- undertaking activities to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted consumer health data or that otherwise threaten to compromise the performance, security, or integrity of our business; and
- performance analytics, identity verification and authorization, site and application optimization, and quality control.
- Recordkeeping and auditing.
- Complying with our legal obligations and risk management, audit, investigations and reporting, and other legal and compliance reasons.
- As otherwise permitted by law or as we may notify you.
We may also collect, use, or disclose consumer health data to prevent, detect, protect against, or respond to security incidents, identify theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal; to preserve the integrity or security of systems; or investigate, report or prosecute those responsible for any such action that it illegal.
Consumer Health Data Sources
We collect consumer health data from the following sources:
Directly from you
When you interact with us on our Platform, responding to an email, visiting us at an in-person promotional event or contacting our Customer Care team), we (or our service providers) may collect the consumer health data you choose to share with us.
From our Affiliates
We may collect via our affiliates, subject to your consent.
Inferences
We may infer certain information about you based on information provided from any of the sources listed above.
Your device
When you visit or interact with our sites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our sites, applications, or services.
Consumer Health Data Disclosures
We do not sell your consumer health data.
We may disclose any of the consumer health data categories listed above to processors, service providers, and contractors that help us provide products and services to you and to our company affiliates, including our holding company A Nelson & Co Limited. We instruct these affiliates, and processors, service providers, and contractors and third parties to only use consumer health data as permitted by our contracts with them and consistent with applicable law.
We may also disclose consumer health data as permitted by applicable law, including, With your consent:
- To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities.
- To a third party; acquiring our assets if Company sells its business or otherwise is part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control of our assets or business.
- To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others.
- To protect your or others' vital interests, including health and safety.
Your Privacy Rights
You have specific rights with respect to your consumer health data. You have the right to:
- Request confirmation that we collect, share, or sell your consumer health data.
- Request access to your consumer health data that we have collected or control, including:
- a list of all third parties and affiliates that we have shared or sold your consumer health data to; and
- the email addresses or other online method to contact those third parties and affiliates.
- Withdraw your consent for our collection and sharing of your consumer health data.
- Request that we delete your consumer health data.
To exercise any of your rights set out above, please contact us at dataprotectionofficer@nelsons.com.
In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
Right to Appeal
In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us on dataprotectionofficer@nelsons.com. If your appeal is unsuccessful, Washington residents can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
Additional Information for Nevada Residents
We do not permit third parties to collect consumer health data over time and across different websites while you use our Platform. Where third-party cookies, pixels or tracking technologies are enabled on our Platform and where consumer health data is collected, such third parties are required to agree to act as our service providers. However, third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device used to access the Platform. Such collection by third parties is not related to NBUSA’s collection of consumer health data from you. We encourage you to view the privacy notices of those third parties for more information about their data practices and your privacy choices with regard to those activities.
If you appeal a denied request and your appeal is unsuccessful, Nevada residents can raise a concern or lodge a complaint with the Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/
Changes in Policy
From time to time, we may change this Policy. We will notify you of any material changes to this Policy as required by law. We will also post an updated copy of this Policy on the Platform. Please check the Platform periodically for updates.
Contact Information
To make an inquiry or comment about this Policy or our privacy practices, contact us at:
Nelsons, 21 High Street #302, North Andover, MA 01845