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Consumer Health Data Privacy Policy

Effective date: October 22, 2026 Last updated: October 22, 2026

What This Policy Covers

This policy describes how Solverein, Inc. (“Solverein,” “we,” or “us”) collects, uses, and shares “consumer health data” as defined by the Washington My Health My Data Act, chapter 19.373 RCW (“MHMDA”), in connection with the solverein.io website and the Medical Ease and Heald platforms (collectively, the “Services”).

Under MHMDA, consumer health data generally means personal information that is linked or reasonably linkable to a covered consumer and identifies that consumer’s past, present, or future physical or mental health status. Covered consumers include Washington residents and individuals whose consumer health data is collected in Washington, when acting in an individual or household context. (app.leg.wa.gov)

This policy does not apply to Protected Health Information (“PHI”) that Solverein maintains as a HIPAA Business Associate on behalf of a Covered Entity. That information is governed by HIPAA and the applicable Business Associate Agreement and is exempt from MHMDA.

When Solverein requests, receives, transmits, or otherwise handles health records directly at an individual’s direction and on that individual’s behalf—and not on behalf of a HIPAA Covered Entity—such information may be consumer health data covered by this policy.

Consumer Health Data We Collect and How We Use It

To the extent the following information qualifies as consumer health data under MHMDA, Solverein may collect:

  • Identifying and contact information, such as name, address, telephone number, email address, and other contact information, when linked or reasonably linkable to health information or a request for healthcare services.
  • Health records and health-related information voluntarily provided through registration, online forms, surveys, use of the Services, or interactions with an artificial intelligence agent.
  • Information concerning requested services, including information needed to retrieve, receive, transmit, or otherwise process health records at the consumer’s direction.
  • Website, browser, and device activity that is linked or reasonably linkable to a consumer and identifies or reveals the consumer’s past, present, or future physical or mental health status or efforts to seek healthcare services.
  • Health-related inferences, including information derived or extrapolated from the categories above, when those inferences qualify as consumer health data under MHMDA.

We collect and use these categories of consumer health data to:

  • provide and operate the Services, products, or transactions requested by the consumer;
  • retrieve, receive, transmit, or otherwise process health records at the consumer’s direction;
  • provide customer service and respond to questions or requests;
  • support and improve the Services;
  • make the Services easier to use;
  • comply with applicable legal and contractual obligations;
  • protect the rights, safety, and security of consumers, Solverein, and others; and
  • establish, exercise, or defend legal claims.

We collect and use consumer health data only to the extent necessary to provide a product or service requested by the consumer, with the consumer’s consent, or as otherwise permitted by MHMDA. (app.leg.wa.gov)

Sources of Consumer Health Data

We may collect consumer health data from:

  • Consumers directly, including through registration, online forms, surveys, requests, use of the Services, interactions with artificial intelligence agents, and directions to request, receive, or transmit health records.
  • Devices and browsers, automatically when consumers use the Services.
  • Healthcare-record sources and electronic health record systems, at the consumer’s direction, including through Flexpa.
  • Authorized persons, when a consumer grants another person access to the consumer’s account or data or authorizes that person to act on the consumer’s behalf.

Consumer Health Data We Share

Depending on the Services requested and the circumstances, the categories of consumer health data we share may include:

  • identifying and contact information linked or reasonably linkable to health information or requested healthcare services;
  • health records and health-related information;
  • information concerning requested services or transactions;
  • website, browser, or device activity that qualifies as consumer health data; and
  • health-related inferences that qualify as consumer health data.

We share consumer health data only to the extent necessary to provide a product or service requested by the consumer, with the consumer’s separate consent where required, or as otherwise permitted by MHMDA. (app.leg.wa.gov)

Under MHMDA, a disclosure to a processor is not statutory “sharing” when the data is exchanged and processed consistently with the applicable processor contract. For transparency, the processor categories that may receive consumer health data are included below.

Categories of Recipients

Solverein may disclose consumer health data to the following categories of recipients, as applicable:

  • Service providers and processors that provide website hosting, website design, technical support, communications, mail or shipping, customer support, and related operational services.
  • Flexpa, which provides electronic health record aggregation services.
  • Professional advisers, including lawyers, accountants, and consultants.
  • Judicial, governmental, regulatory, and law-enforcement bodies, when disclosure is legally required.
  • Contractual counterparties, when disclosure is necessary to comply with legal or contractual obligations.
  • Parties and professional advisers involved in an actual or proposed business transaction, such as a sale, assignment, merger, acquisition, or other transfer of all or part of Solverein’s business.
  • Other parties necessary to protect rights, safety, or security or address legal claims, including parties involved in actual, threatened, or potential legal proceedings.

Your Consumer Health Data Rights

A consumer covered by MHMDA may have the right to:

  • Confirm and access: Confirm whether Solverein is collecting, sharing, or selling the consumer’s consumer health data and access that data, including a list of the third parties and affiliates with which it was shared or sold and available contact information for those recipients.
  • Withdraw consent: Withdraw consent to Solverein’s future collection or sharing of the consumer’s consumer health data.
  • Delete: Request deletion of the consumer’s consumer health data.
  • Appeal: Appeal Solverein’s refusal to act on a request.

When Solverein grants an authenticated deletion request, we will delete the covered consumer health data from our records and notify applicable affiliates, processors, contractors, and other third parties that received the data of the deletion request. Those recipients must honor the request as required by MHMDA. Deletion from archived or backup systems may be delayed as permitted by law. (app.leg.wa.gov)

How to Exercise Your Rights

Submit a request by emailing [email protected]. Please describe the right you wish to exercise and provide the information reasonably necessary for us to authenticate and process your request.

To appeal a decision, reply to the decision or email [email protected] and clearly state that you are submitting an appeal. If we deny the appeal, we will provide a method through which you may contact the Washington State Attorney General to submit a complaint. (app.leg.wa.gov)

Consent and Sale

Solverein does not sell consumer health data.

A sale of consumer health data would require a valid written authorization that is separate and distinct from any consent obtained to collect or share consumer health data. Solverein does not seek such an authorization. (app.leg.wa.gov)

Additional Categories or Purposes

To the extent required by MHMDA, Solverein will disclose and obtain affirmative consent before:

  • collecting, using, or sharing additional categories of consumer health data not disclosed in this policy; or
  • collecting, using, or sharing consumer health data for materially different purposes not disclosed in this policy. (app.leg.wa.gov)

Contact

Email: [email protected] Telephone: 1-843-593-8138