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Consumer Health Data Policy

Last Modified: July 1, 2024

This Consumer Health Data Policy (“CHD Policy”) supplements Spark Health Inc.’s (and its subsidiaries and affiliates) (“Spark”, “we” or “us”) Privacy Policy and applies, to the extent applicable, to “Consumer Health Data” (as defined under applicable law) for residents of Connecticut, Nevada, and Washington under the Connecticut Data Privacy Act (“CTDPA”), the Nevada Consumer Health Data Privacy Law (“NCHD”), and the Washington My Health My Data Act (“MHMD”), respectively, and residents of any other state with similar consumer health data privacy legislation (collectively, “Consumer Health Data Privacy Laws”). In the event of a conflict between any other policy, statement, or notice and this CHD Policy, this CHD Policy will prevail solely with respect to Consumer Health Data. 


This CHD Policy only applies to consumer health data, which is a subset of personal information that identifies your past, present, or future physical or mental health status. This CHD Policy does not apply where an exception or exemption applies, such as for Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Most of the data Spark collects and uses is excluded from Consumer Health Data Privacy Laws because the data is regulated under HIPAA or other exempted laws. 

Consumer Health Data We May Collect

We may collect or receive the categories of personal information, which may be Consumer Health Data if not excluded from Consumer Health Data Privacy Laws:

  • Information about your health conditions, symptoms, status, diseases, diagnoses, testing, or treatments (including surgeries, procedures, use or purchase of medications, or other social, psychological, behavioral, and medical interventions);
  • Measurements of bodily functions, vital signs, symptoms, or other health characteristics;
  • Use or purchase of prescribed medication; 
  • Information regarding gender-affirming care or reproductive or sexual health;
  • Internet or Network Activity Information essential to running our website such as Internet Protocol (IP) address, Media Access Control (MAC) address, operating system and version, and Internet browser type and version which could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health
  • Data that could identify you as an individual seeking health care services; and
  • Any inferences of the above categories of health data that we may infer or derive from non-health related information.

Sources of Consumer Health Data

We may collect these categories of health data directly from you, automatically in the course of our business, including on our website SparkAdvisors.com (our “Website”), through our forms, applications, technology platform (the “Technology Platform”), by phone, texts, or in-person, and any other online offerings that link to this Privacy Policy (collectively, the “Services”), and from other sources, such as public databases and other third parties.

Purposes for Collecting Your Consumer Health Data

To the extent we collect personal information, including consumer health data as described above, we may use this health data as described in Sections 4 and 5 of our Privacy Policy, including to provide you with the Services. We may also use your health data for our business purposes and objectives, including, data analysis; audits; developing new products; improving existing products; identifying usage trends; preventing fraud; and expanding our business activities. Additionally, we may use this health data to comply with applicable law, legal process, respond to requests from public and government authorities, and to protect our rights, operations, and enforce our terms of service. We primarily use your health data for these purposes in connection with providing a product or service you have requested. In some circumstances (e.g., where the purpose is not to provide a product or service you requested), we may collect and use health data with your consent.

Sharing Consumer Health Data With Third Parties 

We may share these categories of health data with third parties as described in Section 5 of our Privacy Policy. We may also disclose health data in connection with a business transfer (such as selling or buying a business unit), to comply with the law, or to protect the safety, rights, or property of our customers, the public, Spark, or others.

How to Exercise Your Rights

To the extent applicable to Spark, Consumer Health Data Privacy Laws provide residents of Connecticut, Nevada, and Washington certain rights with respect to Consumer Health Data, including the following rights, subject to certain exceptions:

  • Request access to your consumer health data.
  • Confirm whether we have disclosed or sold your consumer health data.
  • Delete your consumer health data.
  • Withdraw your consent with respect to consumer health data. 

To exercise any of these rights, please email us at privacy@sparkadvisors.com

If your request to exercise a right under any Consumer Health Data Privacy Law is denied, you may appeal that decision by contacting us.

Washington Residents: If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Contact Information

If you have any questions or comments about this CHD Policy, the ways in which Spark collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable Consumer Health Data Privacy Laws, please do not hesitate to contact us at:

Spark Health Inc.

2218 Broadway #232

New York, NY, 10024

(212) 847-0697