Consumer Health Data Privacy Notice

This Consumer Health Data Privacy Notice (“Notice”) provides information about how Converge Direct, LLC (“Converge,” “we,” “our,” or “us”) collects, stores, and uses your consumer health data (defined below) arising out of or relating to you and/or your use of our Websites. Without limitation, this Notice applies to Connecticut, Nevada, or Washington residents about whom we collect Consumer Health Data, and is intended to provide notices in compliance with the Connecticut Data Privacy Act (“CTDPA”), Nevada SB 370, and Washington’s My Health, My Data Act (“MHMD”). We encourage you to review our Privacy Policy to learn more about our privacy practices and our commitments to you.

This Notice does not apply to third-party websites, products, or services, even if they link to our Websites or our Websites link to them. We recommend you review the privacy practices of those third parties before connecting, accessing third-party websites, and sharing any personal data.

Consumer Health Data We May Collect

For the purposes of this Notice, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual. “Consumer health data” means personal data that is linked or reasonably linkable to you and that identifies your past, present, or future health status or mental health status, as may be applicable. Please note that consumer health data does not include “protected health information” covered by HIPAA.

We may collect, or have collected, the following categories of consumer health data about you:

• Individual health treatments, conditions, treatment, diseases, or diagnosis
• Social, psychological, behavioral, or medical interventions
• Health-related surgeries or procedures
• Use or purchase of prescribed medication
• Diagnosis or diagnostic testing, treatment, or medication
• Gender affirming care information
• Reproductive or sexual health information
• Bodily functions
• Vital signs, symptoms, or measurements of the above categories
• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies
• Data that identifies you seeking health care services
• Any information that we or our service providers process to associate or identify you with the above information that is derived from non-health information (such as inferred data).

Categories of Sources of Consumer Health Data

We may collect consumer health data from the following categories of sources:

• Directly from you, through your interactions with us, such as when you use our Websites, complete electronic forms, or otherwise contact us via chat, email, or phone.
• From third party service providers and our marketing partners, in accordance with applicable law and the context in which you provided the data.

Please note that although we generally use cookies and analytics services for tracking activity on and gauging the effectiveness of our Websites, as well as for third-party advertising purposes, our Websites implement measures to help ensure that we do not use cookies (other than essential cookies for core functionality which need to be active for our Websites to function) for individuals accessing our services from Connecticut, Nevada, or Washington.

How We Use Consumer Health Data

We use the consumer health data we collect about you for the following purposes.

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Websites and our client’s products and services, databases and other technology assets, and business.
• To transfer to our clients who may contact you to provide you with the goods or services described on the Websites.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

To Whom We Disclose Consumer Health Data

We will only disclose your consumer health data with your consent. For example, at your direction, we will provide your data to clients who may contact you to provide you with the goods or services described on the Websites. Under certain circumstances, we may also disclose your data if required to do so by law or in response to valid requests by public authorities.

Consumer Health Data Privacy Rights

Nevada and Washington residents have the following rights in relation to your consumer health data, subject to certain exceptions:

• Right to know. You have the right to know what consumer health data we collect, share, or sell, as those terms are defined under applicable law. You also have the right to obtain a list of all third parties and affiliates with whom we have shared or sold your consumer health data, and an active email address or other mechanism that you may use to contact these third parties. If you are a Washington resident or otherwise subject to Washington law, you also have the right to access your consumer health data that we collect, share, or sell.
• Right to withdraw consent. You have the right to withdraw consent from the collection and sharing of your consumer health data.
• Right to delete. You have the right to request that we, as well as our service providers and contractors, delete the consumer health data that we collect about you.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

Connecticut residents have the following rights in relation to your consumer health data, subject to certain exceptions:

• Right to know and access. You have the right to know what consumer health data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the consumer health data that we collect about you.
• Right to correct inaccurate Consumer Health Data. You have the right to request the correction of inaccurate consumer health data.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out. You have the right to opt-out of targeted advertising, the sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.

How to exercise your rights. If you wish to exercise any of the rights listed above, please send your request(s) using one of the following methods:

• Email: privacy@convergemarketing.com
• Mail: Converge Direct LLC 25 W. 39th St., 6th Floor, New York, NY 10018

We do not charge a fee to process or respond to your verifiable consumer request unless it's excessive, repetitive, manifestly unfounded, or in accordance with applicable law. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How we verify and respond to requests. We will respond to your request via email within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.

However, we cannot respond to your request or provide you with personal data if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal data relates to you. Generally, a rights request must include:

• Sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative, which must include, at a minimum, your first and last name and email address.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.

Our Websites are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we learn we have collected or received personal information from a child under 16 with or without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@convergemarketing.com.

Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity.

How to appeal decisions about your rights.

• Connecticut. If you are a Connecticut resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Connecticut Attorney general at here.
• Nevada. If you are a Nevada resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Nevada Attorney General here.
• Washington. If you are a Washington resident or located in Washington and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Washington State Attorney General here.

Changes to this Notice

We may change this Notice from time to time to reflect new services or changes in our data practices or relevant laws. The “effective date” legend at the top of this Notice indicates when this Notice was last revised. Any changes are effective when we post the revised Notice on the Websites. If we make any material changes to this Notice, we will take reasonable measures to notify you via email and/or a prominent notice on our Websites prior to the change becoming effective and will update the effective date at the top of this Notice. You are advised to review this Notice periodically for any changes.

Contact Us

If you have any questions or concerns about this Notice or wish to exercise one of your privacy rights, please contact us using the following information:

By Telephone (Toll Free)	646-292-5232
By Email	privacy@convergemarketing.com
By Mail	Converge Direct LLC 25 W. 39th St., 6th Floor, New York, NY 10018