Consumer Health Data Privacy Policy

1. Categories of Consumer Health Data We Collect, and Why

We collect this information directly from you — for example, through intake forms, during sessions (in person, or virtually over Zoom), or when you use the Wheel of Life tool. We do not purchase or otherwise obtain consumer health data about you from data brokers or other third-party sources.

A note on our sample Letter of Medical Necessity tool: this downloadable template is pre-filled only with Frey Wellness’s own business information; it does not collect or transmit any information about you, so it is not a source of consumer health data described in this policy. See our general Privacy Policy for more detail.

2. Sources of Consumer Health Data

We collect consumer health data directly from you:

• when you complete an intake form or otherwise share information with your coach, hypnotherapist, or Pilates instructor before, during, or after a session (whether in person or over Zoom);
• when you use the Wheel of Life / Create My Wheel tool on our Site; and
• when you communicate with us by email, through our contact form, or through our client portal (Practice Better) about your health, wellness goals, or services.

We do not collect consumer health data about you from any other source (such as data brokers, advertising networks, or other companies), except as you may separately choose to share information with our booking/payment provider, Practice Better, or our supplement dispensary, Fullscript, which have their own privacy policies.

3. How We Use Consumer Health Data

We use consumer health data only to:

• provide the specific coaching, hypnosis/QHHT, NLP, Pilates, or other service you’ve requested;
• communicate with you about your sessions, goals, or progress;
• generate your Wheel of Life results when you use that tool, and — only if you choose — send them to your own email address, using a small program we run (a Cloudflare Worker) that relays the message through our business email at Google Workspace; this is not stored in any database; and
• keep records as reasonably necessary to provide continuity of care/service and to meet our legal and tax recordkeeping obligations.

We generally retain consumer health data — including coaching and session records — for 7 years after your last session with us, consistent with the recordkeeping obligations described in our general Privacy Policy.

We do not use your consumer health data for advertising, marketing to third parties, or any purpose beyond what’s described above, without first telling you and getting your affirmative consent.

4. Categories of Consumer Health Data We Share, and With Whom

We share consumer health data only with the following categories of third parties, and only as necessary to provide the services you’ve requested:

This is the complete list of categories of third parties we currently share consumer health data with. If we start sharing consumer health data with a new category of third party, we will update this policy first and, where required, obtain your affirmative consent, as described in Section 6.

We do not sell consumer health data. We do not exchange consumer health data for money or any other valuable consideration, and we have no plans to do so. If that ever changes, we will update this policy and will only do so after obtaining your valid, signed authorization as required by RCW 19.373.070.

We do not share consumer health data with third parties for their own advertising or marketing purposes, and we do not permit any geofencing (virtual location-based advertising boundaries) around our practice location or any health care facility, as prohibited by RCW 19.373.080.

5. Your Rights, and How to Exercise Them

If you are a Washington resident, or if your consumer health data was collected while you were in Washington, you have the right to:

• Confirm whether we are collecting, sharing, or (we do not, but confirming) selling your consumer health data, and to access that data, including a list of the specific third parties we’ve shared it with;
• Withdraw your consent to our collection and/or sharing of your consumer health data; and
• Request deletion of your consumer health data, which we will carry out and will also direct any third party we’ve shared it with (see Section 4) to delete, subject to reasonable verification of your identity.

How to submit a request: email us at FreyWellness@freywellness.com, or use our contact form, with “Consumer Health Data Request” in the subject line or message, and let us know which right you’d like to exercise. We may ask for reasonable additional information to verify your identity before acting on your request; we will not require you to create a new account to make a request.

Response time: we will respond to your request without undue delay, and in all cases within 45 days of receiving it. If we reasonably need more time, we may take up to an additional 45 days, and we’ll tell you within the first 45-day period if that’s necessary and why.

If we decline your request, we will explain why, and you may appeal by replying to our decision and asking for a review. We will respond to your appeal in writing within 45 days. If we still decline your request after appeal, we will tell you how to contact the Washington Attorney General’s office to file a complaint (atg.wa.gov).

6. Consent for New Categories or Purposes

If we ever want to collect a new category of consumer health data, or use consumer health data you’ve already given us for a new purpose not described in this policy, we will update this policy to disclose that first and get your affirmative, opt-in consent before doing so.

7. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect consumer health data appropriate to its sensitivity, consistent with RCW 19.373.050. See our general Privacy Policy for our data security and breach-notification practices, which apply to consumer health data as well.

8. Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time. If we make changes, we will post the updated policy here with a new effective date, and — if we’re adding a new category of data collected or a new purpose — we will get your affirmative consent first, as described in Section 6.

9. Contact Us

Frey Wellness LLC
12625 NE Woodinville Dr., Unit 203
Woodinville, WA 98072
FreyWellness@freywellness.com
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