Effective Date: June 25, 2026
Last Updated: June 25, 2026
This PharosLife Consumer Health Data Privacy Policy ("Health Privacy Policy") supplements our Privacy Policy and applies to "consumer health data" subject to certain U.S. consumer health privacy laws such as the Connecticut Data Privacy Act, the Nevada Consumer Health Data Privacy Act, the Washington State My Health My Data Act, and similar state laws (collectively, and as applicable, "Consumer Health Privacy Laws"). Any capitalized but not defined terms in this Health Privacy Policy will have the definitions set forth in the Privacy Policy or in the applicable Consumer Health Privacy Laws.
Consumer health data does not include information that is publicly available, de-identified, or aggregated. What consumer health data we collect may differ depending on your state of residence and how you interact with us.
This Health Privacy Policy does not apply to "protected health information" ("PHI") regulated by the Health Insurance Portability and Accountability Act ("HIPAA"). PharosLife is not a health care provider, health plan, or other entity covered by HIPAA, and we do not create or maintain PHI. To the extent any information you provide to us is also held by your health care provider as PHI, your provider's handling of that PHI is governed by HIPAA and that provider's own privacy practices, not by this Health Privacy Policy.
1. Consumer Health Data We Collect
"Consumer health data" is defined broadly under state law, so many of the different types of information we collect could also be considered consumer health data. What we collect may differ depending on your state of residence and how you interact with the Services. Examples of consumer health data may include:
- Planning inputs, life-event categories, notes, and checklists that relate to your or a loved one's past, present, or future physical or mental health condition or status.
- Information that could identify your efforts to seek or receive health-related services or support.
- Other information that may be used to infer or derive data related to the categories above.
2. Sources and How We Use Consumer Health Data
We collect consumer health data from the following categories of sources: (i) directly from you, when you choose to provide it through the Services — for example, when you create planning inputs, complete checklists, or contact our support team; and (ii) automatically from your activity within the Services, from which we may infer related information.
We collect and process the categories of consumer health data described in Section 1 only as reasonably necessary for the following purposes: (i) to provide and maintain the features and services you request and authorize; (ii) to respond to your inquiries and support requests; and (iii) to comply with our legal obligations. This may include delivering and operating the Services and their features, personalization of certain features, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the products, and other essential business operations that support the provision of the Services.
We do not use consumer health data for purposes that are incompatible with those described in this Health Privacy Policy without first obtaining your consent.
3. How We Share Consumer Health Data
We do not sell consumer health data. We do not share consumer health data, except with your consent or as reasonably necessary to provide a feature or service you have requested. Where we share consumer health data, we share it with the following categories of third parties:
- Service providers that act as our processors and perform functions on our behalf, such as hosting, data storage, and analytics, and that are bound by a written contract requiring them to protect your consumer health data, to process it only for the purposes for which we engaged them, and not to use it for their own purposes.
- Government or regulatory authorities, where required to do so by valid legal process and only to the extent the disclosure is legally required (i.e., a subpoena, court order, or warrant that is facially valid and properly issued by a court of competent jurisdiction), or where information is made known to us that reasonably indicates disclosure is necessary to prevent an imminent risk of death or serious physical injury to any individual, and only to the extent necessary to address that risk.
4. Analytics and Session Recording
When you use the Services, analytics and session-recording technologies may capture your activity on pages where you view or enter consumer health data — including health-related information such as conditions, medications, care preferences, and directives. We use these technologies to understand and improve how the Services function. This data is processed on our behalf by analytics service providers, such as Mixpanel, Inc., which act as our service providers and are bound by contract to process this data only for the purposes for which we engage them. These recordings are limited to behavioral interaction data only. Sensitive information, such as the consumer health data you input, is not captured.
We collect this information solely to operate, analyze, and improve the features and usability of the Services. You may withdraw your consent at any time through our Cookie Preferences / Privacy Settings.
5. AI Chatbot and Consumer Health Data
When you use our AI chatbot to ask about your health-related information, the information you enter is consumer health data, and it is processed to help you retrieve and navigate information you have already provided. This data is processed on our behalf by our AI provider, OpenAI, acting as our service provider. Your inputs are not used to train OpenAI's models and are retained only as necessary to provide the feature.
We process this consumer health data solely to help you locate, retrieve, and understand information you have already entered into the platform. The assistant does not provide medical, diagnostic, or legal advice.
6. Data Security
We maintain administrative, technical, and physical safeguards designed to protect consumer health data, and we restrict access to that data to the personnel, processors, and contractors who need it to carry out the purposes described in this Health Privacy Policy.
7. Consumer Health Data Rights
If you are a Connecticut, Nevada, Washington, or Virginia resident, you may have rights with respect to your consumer health data as described below. Your rights may be subject to certain conditions and exceptions under Consumer Health Privacy Laws.
- Access and Portability: You may have the right to request confirmation of whether or not we are processing your consumer health data and to access your consumer health data and request a copy of your consumer health data in a machine-readable format, to the extent technically feasible. If you are a Nevada or Washington resident, you may also request a list of all Third Parties and Affiliates with whom we have disclosed your consumer health data and their contact information.
- Correction: You may have the right to correct inaccuracies in your consumer health data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your consumer health data.
- Deletion: You may have the right to request that we delete the consumer health data that we have collected about you.
- Opt-Out of Sale, Targeted Advertising, and Profiling: You may have the right to opt-out of sale and/or processing of your consumer health data for targeted advertising and profiling purposes, however, we do not conduct such activities using your consumer health data.
- Consent: You may have the right to consent prior to our collection, processing, and/or disclosure of your consumer health data, including but not limited to reproductive or sexual health information. You have the right to withdraw your consent for such collection, processing, and/or disclosure of your consumer health data at any time by contacting us at privacy@mypharoslife.com. Withdrawing your consent will not affect the lawfulness of any processing we carried out before you withdrew it.
- Nondiscrimination: You have the right not to be discriminated against for exercising your rights as described above.
- Verification: Before we act on your request, we will take reasonable steps to verify your identity, which may include asking you to confirm information associated with your account. We will not require you to create a new account in order to exercise your rights. If we cannot verify your identity using commercially reasonable efforts, we may decline to act on your request and may ask you for additional information reasonably necessary to authenticate you.
- Appeal: If we refuse to take action on your request within a reasonable period of time after receiving your request in accordance, you may appeal our decision by contacting us at privacy@mypharoslife.com. If we deny your appeal, you have the right to contact the attorney general of your state of residence (CT, NV, and WA).
8. How to Exercise Your Rights
To exercise any of your rights under Consumer Health Privacy Laws, please contact us at privacy@mypharoslife.com, tel:1-510-358-8939.