De-identified data can be used and shared for business purposes
Function may aggregate, de-identify or anonymize collected health data, including by removing identifiers, aggregation or obfuscation in compliance with applicable law. It may use and share the resulting information for lawful business purposes, including service improvement, promotion and research. Subject to applicable law, the policy treats such information as outside consumer health data. Function says it will not attempt re-identification except as required or permitted by law.
Supporting quotations
Consumer Health Data we may create, infer or generate. We may create, infer or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. We may create aggregated, de-identified, and/or anonymized information from Consumer Health Data by removing certain data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation or other means. For example, we may de-identify any information and data provided and/or generated in connection with your use of our Services (including without limitation your health-related data), in compliance with applicable law. Except as required or permitted by applicable law, we will not attempt to re-identify any data that has been aggregated, de-identified, and/or anonymized. Subject to applicable law, our use of such aggregated, de-identified, and/or anonymized information is not Consumer Health Data.
To create aggregated, de-identified and/or anonymized data: We may create aggregated, de-identified and/or anonymized data from your Consumer Health Data and other individuals whose Consumer Health Data we collect. We make Consumer Health Data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, promote our business, and for research purposes. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Cross-references
qualifies (model-proposed): Which categories may feed de-identified business data — qualifies: The table’s de-identified business-data use is read with the policy’s legal qualifications and commitment not to attempt re-identification except where law requires or permits it.
Use & Processing · Context
The listed uses are examples within this policy’s scope
Function says it uses consumer health data for the purposes in this policy or otherwise disclosed to you. These rules apply to the extent required by applicable US state laws and exclude processing on behalf of enterprise customers. The table presents examples rather than an exhaustive purpose list.
Supporting quotations
We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:
This Consumer Health Data Privacy Policy (“Consumer Health Data Privacy Policy”) describes how Function Health, Inc. and its corporate affiliates (collectively, “Function,” “we,” “us” or “our”) process consumer health data as applicable US state laws may define that term (“Consumer Health Data”), that we collect through our digital or online properties or services that link to this Consumer Health Data Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, and other activities described in this Consumer Health Data Privacy Policy (collectively, the “Service”). This Consumer Health Data Privacy Policy applies to the extent required by applicable US state laws.
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.
Use & Processing · Company practice
Data used to operate and support the Service
For covered consumer health data, Function lists providing the Service and security features, maintaining profiles, service communications, support and responding to requests, questions and feedback. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Service delivery and operations: providing the Service, enabling security features of the Service, establishing and maintaining your user profile on the Service, communicating with you about the Service, providing support for the Service and responding to your requests/questions/feedback. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Use & Processing · Company practice
Data used to personalize the Service
Function lists understanding needs and interests, personalizing the Service and related communications, and remembering webpage choices and preferences. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Service personalization: understanding your needs and interests, personalizing your experience with the Service and our Service-related communications, remembering your selections and preferences as you navigate webpages. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Use & Processing · Company practice
Research, insights and product development
Function lists insights, including research, and development to analyze and improve the Service and business and develop new products and services. This row is not limited to de-identified data. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Insights and development: for insights (including research) and development purposes, including to analyze and improve the Service and our business and to develop new products and services. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Use & Processing · Company practice
Health and other listed data can support direct marketing
Function lists communicating about services, upcoming events and other information as direct marketing. The row expressly includes health-related and genetic data; it is not limited to contact details. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Direct marketing: communicating with you about services, upcoming events, and other information. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Use & Processing · Company practice
Data used for promotions and contests
Function lists administering promotions and contests and communicating about those in which you participate. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Promotions and contests: to administer promotions and contests and to communicate with you about any such promotions or contests in which you participate. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.
Use & Processing · Company practice
Service and business analytics
Function lists analyzing Service usage, page popularity, navigation and email interactions, improving the Service and the rest of its business, and developing new products and services. The row lists contact, demographic, account, service-eligibility, health-related, genetic, audiovisual, transactional, communications, relationship, payment, marketing and user-content data, plus device, precise-location, online-activity and communication-interaction data.
Supporting quotations
Service improvement and analytics: analyzing your usage of the Service, improving the Service, improving the rest of our business, helping us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and developing new products and services. Contact data, demographic data, account data, service-eligibility data, health-related data, genetic data, audiovisual recording data, transactional data, communications data, relationship data, payment data, marketing data, user-generated content data, device data, precise geolocation data, online activity data, communications interaction data.