Consumer Health Data Privacy Disclosure

Last Revised: May 9th, 2025

This Consumer Health Data Privacy Disclosure (“CHDP Disclosure”) supplements the Caily LLC (“Company”, “we”, “us”, “our”) Services Privacy Policy. The Services Privacy Policy describes the personal information that we collect and the sources from which we collect it. This additional disclosure is required by applicable U.S. consumer health data privacy laws, including but not limited to Washington’s My Health My Data Act (“MHMDA”), Nevada’s Consumer Health Data Privacy law (“NV CHDP”), the Connecticut’s Consumer Data Protection Act, as amended (“CTDPA”) (collectively “CHDP Laws”), and applies only to personal information that may be considered “Consumer Health Data” under such CHDP Laws.

While some of the information you provide or access through the Platform may be health-related, the Platform and any information you provide directly to it is not subject to the Health Insurance Portability and Accountability Act (“HIPAA”), nor is any information “protected health information” as defined under HIPAA.

PRIVACY POLICY; TERMS AND CONDITIONS

This CHDP Disclosure is incorporated by reference and should be read in conjunction with the Company’s (1) Services Privacy Policy and (2) Services Terms and Conditions.

CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT

Depending on which of our products and services you interact with and the choices you make, we may collect personal information that may be considered Consumer Health Data. Consumer Health Data is personal information relating to the past, present, or future physical or mental health of an individual. We may collect the categories of Consumer Health Data listed in the chart below from visitors and users of the Platform, our products or services. We may also collect and process information or draw inferences from any of the categories of Consumer Health Data identified below. The “Disclosed” column below details what categories of Consumer Health Data will be disclosed and to which category of third parties.

Please note that the information you provide us depends on what services you use and what you may provide to us on the Platform. For example, our Vault allows you to upload various types of documents and information. It is ultimately up to you as to what information you upload or otherwise provide to us on the Platform

Category Examples Collected Who Has Access
Individual health conditions, treatment, status, diseases or diagnoses Information collected to treat certain conditions, self-reported information to evaluate likelihood of health conditions YES– Your Circle Members; Service Providers.
Social, psychological, behavior or medical interventions Information inputted as part of virtual behavioral health treatment YES– Your Circle Members; Service Providers.
Health-related surgeries or procedures Location information that could reasonably indicate a person’s attempt to acquire health-related surgeries or procedures, information obtained from cross-context behavioral advertising or other tracking information that could reveal efforts to research or obtain health-related surgeries or procedures. YES– Your Circle Members; Service Providers.
Use or purchase of medication Information inputted for medication delivery services, information obtained from cross-context behavioral advertising or other online tracking information that could reveal efforts to use or purchase medication. YES– Your Circle Members; Service Providers.
Bodily functions, vital signs, symptoms or measurements of information Information obtained from devices that collect bodily functions, vital signs, symptoms or measures such as heart monitors, fitness trackers, pedometers YES– Your Circle Members; Service Providers.
Diagnoses or diagnostic testing, treatment or medication Information inputted as part of health prevention calculators, diagnostic tests, or other health-related assessments YES– Your Circle Members; Service Providers.
Gender-affirming care information Location information that could reasonably indicate a person’s attempt to acquire gender-affirming care services (e.g., hormone therapy, social, psychological, behavioral, cosmetic medical or surgical interventions), efforts to research or obtain gender-affirming care services. YES– Your Circle Members; Service Providers.
Reproductive or Sexual health information Location information that could reasonably indicate a person’s attempt to acquire or receive sexual or reproductive health services (e.g., menstrual cycle tracking, ovulation tracking, performance enhancing medications), efforts to research or obtain reproductive or sexual health services. YES– Your Circle Members; Service Providers.
Biometric data Identifying information, such as physical patterns and sleep, health, or exercise data through connected third party devices, such as smart watches. YES– Your Circle Members; Service Providers.
Genetic data Data directly resulting from the sequencing or a portion of the deoxyribonucleic acid (DNA), genotypic or phenotypic information resulting from DNA, data concerning the health of a person that is analyzed in connection with DNA; self-reported health data that a person submits that is analyzed in connection with DNA. YES– Your Circle Members; Service Providers.
Location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies Location information revealing a person near a pharmacy, hospital, clinic, etc. YES– Your Circle Members; Service Providers.


We obtain the categories of Consumer Health Data listed above from the following categories of sources:

  • Directly from you. For example, when you: 
    • track appointments, events, or other tasks;
    • upload documents or photos;
    • chat with other family members or caregivers within the Platform; 
    • fill out or complete any forms or other free-text fields on the Platform; 
    • connect the Platform with any third party software or platforms that are supported; or
    • otherwise communicate with us, such as contacting us for more information. 
  • Indirectly from you. For example, through information we collect from you in the course of providing our services to you. 

Directly and indirectly from activity on our Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section in our Services Privacy Policy.

USE OF YOUR CONSUMER HEALTH DATA 

We may use Consumer Health Data, such as described above, for the purpose of:

  • providing the products and services you request from us;
  • security, credit or fraud prevention purposes;
  • providing you with effective customer service;
  • providing you with a personalized experience when you use the Platform;
  • developing new products and services;
  • to provide you support when responding to your questions, concerns, complaints, or other requests;
  • to process your payments for your subscription or other purchases;
  • contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
  • contacting you with information and notices related to your use of the Platform;
  • inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
  • better understanding your needs and interests;
  • improving the content, functionality and usability of the Platform;
  • improving our products and services;
  • improving our marketing and promotional efforts; and
  • any other purpose identified at the point of data collection, in an applicable privacy notice, in a click-through agreement or in any other agreement between you and us.

DISCLOSURE OF YOUR CONSUMER HEALTH DATA 

WE DO NOT SELL YOUR CONSUMER HEALTH DATA. We do not sell or disclose your personal information, including Consumer Health Data, to others except as provided herein. We only disclose Consumer Health Data as directed by you, for the purpose of providing the products and services you request from us, or as explained in this section.

Disclosing as Described in our Privacy Policy. As described in our Services Privacy Policy, we may disclose personal information, including Consumer Health Data, in connection with business transfers (for example, as part of a merger) or for the protection of Company or others (although we do not disclose consumer health data for reasons related to credit risk). 

Service Providers. We may also employ other companies and individuals to perform functions on our behalf. These service providers may have access to Consumer Health Data needed to perform their functions, but may not use it for other purposes. As described in our Services Privacy Policy, “Service Providers” may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing. 

Your Members. As part of our services on the Platform, you may add members to your Circle or provide certain individuals with access to your Consumer Health Data. These individuals may include your family members, friends, or other caregivers (“Members”). We may disclose your Consumer Health Data with your approved Members, or your approved Members may have access to your Consumer Health Data. Company is not responsible or liable for any uses of your Consumer Health Data or your content by your Circle Members.

Government agencies. When we receive a lawful request from a government agency, including law enforcement, we may disclose your consumer health data if necessary to comply with that request.

Business transfer. If we are involved in a merger, acquisition, asset sale, or other corporate combination, your consumer health data may be transferred to the acquiring or surviving entity.

Other third parties. We may share your Consumer Health Data with other third parties with your consent or, if necessary, we may share your Consumer Health Data in certain circumstances to protect our rights, our customers, or your safety.

YOUR CHDP LAW RIGHTS 

The CHDP Laws provide consumers with additional rights with respect to their Consumer Health Data. Any Consumer Health Data we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you are a Connecticut, Nevada or Washington consumer, you may exercise each of your rights as identified below, subject to our verification of your identity.

  1. Confirmation/Access.  You have the right to confirm whether we are collecting, selling or disclosing your Consumer Health Data and to access such information. If we sell or disclose your Consumer Health Data, you may also request a list of all third parties and Company affiliates with whom we have disclosed or sold your Consumer Health Data and receive an active email address or other online mechanism to contact these third parties.   
  2. Withdraw Consent/Authorization. You have the right to withdraw consent from the collection and disclosing of your Consumer Health Data at any time. If we sell your Consumer Health Data, you may also withdraw your previous authorization to the sale of such data. 
  3. Deletion.  You have the right to request that we delete any of your Consumer Health Data, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Consumer Health Data from our records, unless an exception applies.  Where applicable, we will ensure such changes are shared with trusted third parties.
  4. Non-Discrimination. The right not to receive discriminatory treatment for the exercise of the privacy rights described above.

How to exercise your rights related to Consumer Health Data. If you are a Connecticut, Nevada or Washington resident, you may exercise any of the rights listed above by: 

  1. Submitting a request via email at [email protected]; or
  2. Calling us at +1 (888) 629-8085 to submit your request.

Responding to your Requests. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Consumer Health Data. 

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.  In some cases our ability to uphold these rights for you may depend upon our obligations to process Consumer Health Data for compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.  

Appeal. 

  • Connecticut. If you are a Connecticut resident and your request is denied, you may appeal our decision by emailing us 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 the appeal is denied, you may submit a complaint with the Connecticut Attorney general at https://www.dir.ct.gov/ag/complaint/.
  • Nevada. If you are a Nevada resident and your request is denied, you may appeal our decision by emailing us 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 at https://ag.nv.gov/Complaints/File_Complaint/.
  • Washington. If you are a Washington resident or located in Washington and your request is denied, you may appeal our decision by emailing us 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 at https://www.atg.wa.gov/file- complaint. 

CHANGES TO THIS CHDP DISCLOSURE

This CHDP Disclosure may be amended from time to time and we shall post the revised CHDP Disclosure on our Platform. Changes will be effective upon posting. 

CONTACT US

We value your opinions and welcome your feedback. To contact us about this Policy or your Consumer Health Data, please contact us by email at [email protected].