Consumer Health Data Privacy Policy

Function Health · agreement dated August 1, 2025 · Official agreement

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Data Access & Collection · Company practice

Contact and demographic information you may provide

The policy lists contact information such as your name, email, phone and billing or mailing addresses, and demographic information such as residence, age, date of birth, gender identity, race or ethnicity and sexual orientation, among the consumer health data you may provide through the Service or otherwise.

Supporting quotations

Consumer Health Data you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
Demographic data, such as your city, state, country of residence, postal code, age, date of birth, gender or gender identity, racial or ethnic identity, and sexual orientation.

Data Access & Collection · Company practice

Profile and account information

You may provide account information including login credentials, date of birth, biography, a photograph, social-profile links, preferences, promotion or survey participation, and other details you add to your profile.

Supporting quotations

Account data,such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph or picture, links to your profiles on social networks, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.

Data Access & Collection · Company practice

Information to establish benefit eligibility

If you use the Service as an enterprise-customer benefit, you may provide the employer or customer name, eligibility information and relevant customer identification number. The policy separately excludes processing on behalf of enterprise customers; it does not say all information a benefit user provides falls outside this policy.

Supporting quotations

Service-eligibility data, if you are accessing the Service as part of an enterprise customer-provided benefit, you may provide us with relevant information such as your employer or other enterprise customer name, eligibility data, and relevant enterprise customer identification number.
This Consumer Health Data Privacy Policy does not apply to Consumer Health Data that we process on behalf of our enterprise customers while providing Function services to them. For example, to the extent that we receive your Consumer Health Data from your employer related to your eligibility for our Service, our use of that Consumer Health Data may be governed by our agreements (including, as applicable, a business associate agreement) with the relevant enterprise customer. If you have questions regarding your Consumer Health Data that we process on behalf of an enterprise customer, please direct your questions to the relevant enterprise customer.

Data Access & Collection · Company practice

Health records, lab information and connected devices

Health data you may supply includes mental or physical history, conditions, diagnoses, treatments, medications, medical images, biomarkers, samples, lab results and clinical notes. It can come from self-report forms, uploaded medical records or a wearable or Internet of Things device you link to the Service.

Supporting quotations

Health-related data, such as mental or physical history, conditions and diagnoses, treatments, medications, medical images, biomarkers, lab samples, lab results, clinical notes, and other physical or mental health information. This may include personal information that you provide directly to us when you complete electronic forms designed for you to self-report your physical or mental health status, upload medical records, or link a wearable or Internet of Things device to our Services.

Data Access & Collection · Company practice

Some lab tests may produce genetic data

Certain available lab tests may produce data about inherited characteristics. The policy describes this as genetic data; it does not say every test produces it.

Supporting quotations

Genetic data, certain of the lab tests available through the Service may produce data that relates to inherited characteristics.

Data Access & Collection · Company practice

Audio and video recordings

The listed data includes audio and video recordings of you that you may provide through the Service or otherwise.

Supporting quotations

Audiovisual recording data, such as video and audio recordings of you.

Data Access & Collection · Company practice

Order and payment information

Function lists order numbers, transaction history and information needed to complete orders, along with payment information needed for transactions, including card information or a bank account number.

Supporting quotations

Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number.

Data Access & Collection · Company practice

Messages and marketing engagement

Listed data includes exchanges with Function through the Service, chat, social media or other channels, plus marketing preferences and details of engagement with marketing communications.

Supporting quotations

Communications data based on our exchanges with you, including when you contact us through the Service, chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

Data Access & Collection · Company practice

Your relationship to other people

Function lists information about your familial or other relationship to third parties whose personal information you may provide.

Supporting quotations

Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.

Data Access & Collection · Company practice

User content and its metadata

Function lists content you generate, transmit or make available on the Service, such as photos, music, videos, comments, questions and messages. It also lists metadata describing how, when, where and by whom content was collected or edited, including keywords and geographic or location information added to the content.

Supporting quotations

User-generated content data, such as photos, images, music, videos, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.

Data Access & Collection · Company practice

The list of collected data is not exhaustive

Function may collect other data beyond the listed types and says it will use that data as described in this policy or as otherwise disclosed when it is collected.

Supporting quotations

Other data not specifically listed here, which we will use as described in this Consumer Health Data Privacy Policy or as otherwise disclosed at the time of collection.

Data Access & Collection · Company practice

Device identifiers and general location

When you use the services, Function collects information through tracking technologies that may be consumer health data. Examples include device and browser details, operating system, hardware specifications, IP address, unique and advertising identifiers, language, carrier and network details, and general location such as city or state.

Supporting quotations

Consumer Health Data we collect automatically. When you use our services, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:
Device data,such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

Data Access & Collection · Company practice

Precise location requires app permission

Function lists precise geolocation data when you authorize its mobile app to access your device location. This differs from general location included in device data.

Supporting quotations

Precise geolocation data, when you authorize our mobile application to access your device’s location.
Device data,such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

Data Access & Collection · Company practice

Website, app and communication activity

Function lists pages or screens viewed, time spent, prior website, navigation paths, on-page activity and access timing, plus email opens and link clicks. It may track email, text and other communication interactions, including email opening or forwarding, using invisible pixel tags in emails.

Supporting quotations

Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Communication interaction data suchas your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Data Access & Collection · Company practice

Affiliates, labs, providers and other data sources

Function also obtains the described types of consumer health data from third parties. Examples include corporate affiliates such as Ezra AI, Inc. and Ezra Health of Florida, PLLC; healthcare, lab and medical-adjacent providers; third parties you designate, including labs without a Function contract; and providers collecting or supplying data for work on Function’s behalf.

Supporting quotations

Consumer Health Data we obtain from third-party sources. We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:
Corporate affiliates. We may obtain your Consumer Health Data from our corporate affiliates (including Ezra AI, Inc. and Ezra Health of Florida, PLLC).
Lab and Provider Partners, including third party healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
Third parties that you designate such as lab providers with whom we do not have a contractual relationship.
Service providers. Third parties that collect or provide Consumer Health Data in connection with work they do on our behalf.

Data Access & Collection · Company practice

Employers and other enterprise customers can supply data

The source list includes enterprise customers such as employers and gyms that may provide personal information. The separate policy-scope exclusion for processing on behalf of enterprise customers still applies.

Supporting quotations

Our enterprise customers, such as employers, gyms and other entities that may provide us with your personal information.

Data Access & Collection · User right or choice

Withdraw consent for future collection or sharing

Where Function relies on consent for collection or sharing, you can withdraw it for future collection or sharing. If required health data is affected, Function may be unable to provide the services that need it. These rights depend on applicable law, may have limitations such as a charge, and requests may require identity verification.

Supporting quotations

Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.
Declining to provide information. We need to collect Consumer Health Data to provide certain services. If you do not provide the information we identify as required or mandatory or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services.
You may have certain rights to your Consumer Health Data under applicable law. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge). If you wish to exercise these rights, please email us at privacy@functionhealth.com.
To exercise your rights above and make a Consumer Health Data rights request, please email us at privacy@functionhealth.com. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.