This Consumer Health Data Privacy Notice (this “CHD Privacy Notice”) addresses how Greenway processes consumer health data as defined under applicable state laws such as the Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective, including any regulations thereunder (collectively, “Consumer Health Data Laws”). This CHD Privacy Notice supplements other Privacy Statements that may be attached to websites and applications that you are using. In the event of a conflict between any other policy, statement, or notice and this CHD Privacy Notice will prevail as to Consumer Health Data collected under the Consumer Health Data Laws.
What is and is Not Consumer Health Data
Consumer health data is personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status, such as: (i) individual health conditions, treatment, diseases, or diagnosis; (ii) social, psychological, behavioral, or medical interventions; (iii) health-related surgeries or procedures; (iv) use or purchase of prescribed medication; (v) diagnoses or diagnostic testing, treatment, or medication; (vi) information relating to researching, obtaining, or seeking gender affirming care services; (vii) reproductive or sexual health information; (viii) data that identifies a consumer seeking health care services or status; or (ix) information used to associate or identify a consumer with the information described in (i) - (viii) above that is derived or extrapolated from non-health information. Consumer health data does not include publicly available information, de-identified data, protected health information under HIPAA. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Categories of Consumer Health Data We Collect
We may collect and use your consumer health data with your explicit consent or as reasonably necessary to provide services that you have requested from us or that your are using that are provided by us. This may include using your consumer health data to establish and maintain our relationship with you (including acting upon any of your requests), to customize or improve services offered to you, to comply with applicable legal, regulatory or professional requirements, and to protect our rights or property and that of our users.
If you are a consumer in a state with a Consumer Health Data Law, this CHD Privacy Statement gives you the information required under such Consumer Health Data Laws. Please note that Greenway also provides some HIPAA-regulated products and services to HIPAA “covered entities.” The HIPAA-regulated “protected health information” gathered by these products is not covered by this CHD Privacy Statement. This CHD Privacy Statement also does not apply to the www.greenwayhealth.com website as it does not collect consumer health data.
Categories of Consumer Health Data Collected, Why We Collect such Data and How the Data Will be Used
When you are using a Greenway solution or application, we may collect the categories of consumer health data, and use them for the purposes, set forth in the following table:
| Categories of Consumer Health Data | Purpose of Collection and Use |
|---|---|
| Information from your health care provider, including health information you entered into your healthcare provider’s intake forms on the Greenway platforms and applications, as well as information that your healthcare provider has gathered and included in your medical, insurance or appointment records. | We may collect this information to share personalized health-related materials with you, to plan and select the content on our platforms and applications, to measure the effectiveness of content shown to you, to create de-identified health information, and to provide security. |
| Information you voluntarily enter into the Greenway platforms and applications. | Some of our platforms and applications offer to collect information from you as part of our product offerings to you. For example, you may answer survey questions about your experiences with a health product, provide contact information for follow-up from a third party about a health-related topic or provide feedback to us about how our products work. |
| Information about the personalized health-related materials you see. | We collect this information to share personalized health-related materials with you, to plan and select the content on our platform, to measure the effectiveness of content shown to you, to create de-identified health information, and to provide security for your information. |
| Technical information that helps our product function, for example, information from your browser, computer, or mobile device as you continue to interact with Greenway’s products or services. This information includes device and network information, log files and analytics information. Greenway also makes use of log files, which include IP addresses, browser type, date/time stamp, and number of clicks. | |
| Information you provide in the course of user support inquiries and to fulfill privacy requests (such as the provider at which you were using our platform when you signed an optional consent that you later exercise your right to revoke). | If you provide us consumer health data in this context, we use it to respond to your inquiry, or to fulfill your request, as applicable. |
We may derive or infer information relating to your health interests, conditions, treatment needs, or healthcare utilization based on your interactions with our platforms, appointment activity, communications, or use of features. We retain Consumer Health Data only as long as reasonably necessary. We do not use geo-location tracking functionality.
Categories of Sources from Which Consumer Health Data is Collected
We collect consumer health data from your healthcare provider when it is provided to us.
We also collect consumer health data from your use of our platforms and applications. We collect this information to the extent necessary to provide a product or service that you have requested from us.
Finally, we may also collect consumer health data from you or your authorized representative if you or your authorized representative submit such data in connection with a user support inquiry or to make a privacy request of us.
Categories of Consumer Health Data that are Shared
Some personalized health-related materials we show you may offer you the ability to receive additional communications from the sponsor of the materials. For example, a pharmaceutical manufacturer who makes a medicine may sponsor a message about that medicine that you see, and ask if you would like to receive additional communications about the medicine directly from them. You are never required to agree to receive any communications directly from sponsors. Any opportunity to receive additional communications describes what consumer health data you would be sharing (such as your name and email address) and for what purpose. If, after reading this explanation, you decide that you want to share some of your consumer health data with the sponsor, then we will complete your request. This request is distinct from the consent under which we collect consumer health data (the HIPAA Authorization). The information shared is always set forth in the applicable request, but generally consists of your contact information and information about the campaign you saw so that the sponsor can provide the additional information you have requested.
List of Categories of Third Parties and Specific Affiliates with Which We Share Consumer Health Data
- Sale: We do not knowingly sell your consumer health data for monetary compensation.
- Your Request: We only share your consumer health data with your prior express written direction to third parties you select (for example, to the sponsors of content from whom you request follow-up communications).
- Affiliates: We may share consumer health data within our family of companies, including Greenway Health India Pvt, Ltd and our private equity owner, Vista Private Equity, LLP.
- Business Organizations: We may disclose your consumer health data in connection with any business combination, securities offering, bankruptcy, reorganization, dissolution or other similar transaction. In such case, your consumer health data would remain subject to the provisions of this CHD Privacy Statement, unless amended as described below.
- Legal and Government Access: We will share your consumer health data with law enforcement, government agencies, or private litigants if such a disclosure is required by a valid and legally binding request. If we receive a law enforcement request for your consumer health data, we will try to inform you by providing you a notice by sending an email to you at an email address we have on file for you, unless the law does not allow us to provide this notice to you.
- Cloud hosting providers: We will share your consumer health data with cloud hosting providers as part of providing the services.
Your Rights Regarding Consumer Health Data
If you are a resident of a state with a Consumer Health Data Law, you may have the right to (1) request access to your consumer health data; (2) confirm whether we have disclosed or sold your consumer health data; (3) delete your consumer health data; (4) withdraw your consent or authorization relating to such data, and (5) appeal any decisions we make with respect to your requests.. You can exercise your rights by using the contact methods provided below.
Changes to This Privacy Statement
Greenway Health reserves the right to amend this Privacy Statement at our discretion and at any time. Unless otherwise noted, any such changes will be immediately incorporated into this Privacy Statement, and the “Date Last Updated” below will show when the latest changes were made. You should review the page often to ensure you have the most up-to-date information. Your continued use of our Sites following any changes indicates your consent to the terms and practices described in the most-current version of this Privacy Statement.
As related to any updates, Greenway may periodically make updates to describe how new Web features may affect our use of your information and to let you know of new controls and features that we may provide you. Greenway will NOT apply changes to this Privacy Statement retroactively to information Greenway has previously collected.
Contact Information
If you have any questions or comments about this Consumer Health Data Privacy Notice, including a request to receive this Consumer Health Data Privacy Notice in an alternative format, or the ways in which Greenway Health collects and uses your information, or any rights regarding such collection or use, you may contact us at:
Web Form link: https://www.greenwayhealth.com/consumer-privacy-request
Postal Address:
Greenway Health
Attn: Privacy Officer
4301 West Boy Scout Blvd, Suite 800
Tampa, Florida 33607
Greenway Health Consumer Health Data Privacy Notice
Last Updated: May 20, 2026