Centr Consumer Health Data Policy

Effective Date: October 15, 2024

Certain U.S. states such as Washington and Nevada have laws requiring companies that process data under the broad umbrella term of “consumer health data” (“CHD”) publish a policy notifying people about how they collect, use, and share (collectively “process” or “processing”) CHD and the rights certain consumers (“Consumer”, “Consumers”, "you", or "your") may have.

This Consumer Health Data Policy (“CHDP” or “Policy”) supplements Centr’s U.S. States Privacy Notice, the Centr Privacy Policy Page and our Centr Cookies and Tracking Technologies Disclosure (collectively, "Policies") and applies solely to Consumers in states with laws pertaining to Consumer Health Data and specifically require such policies. This CHDP applies to any website, application, feature, widget or other online service that is owned or controlled by Centr LLC, its subsidiaries and affiliated companies including that post a link to this Privacy Policy (collectively, “Centr”). This CHDP applies only to CHD (as defined by applicable law) that is processed by Centr in the course of our business, including via the Centr websites, and through our Apps, , and other online or offline offerings (together, with any and all future online and offline offerings operated by or on behalf of Centr, the “Services”).

1. CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT

As described in the “WHAT PERSONAL INFORMATION WE COLLECT" sections of our Privacy Policy, the CHD categories we collect depends on the context of your interactions with Centr, the features you use, the choices you make (including your privacy settings), and applicable law.

Connected Devices/Accounts. We enable you to connect your Centr account with third parties (i.e. devices, apps, APIs, or websites that integrate with the Services). Where you choose to connect another company's device or account to your account, or engage in our Services that features a partnership with a third party, we may, with your consent, collect information from your use of the connected device(s) to facilitate interaction with our Services. This may include information like heart rate or calories burned that may be considered consumer health information under certain applicable laws.

2. SOURCES OF CONSUMER HEALTH DATA

As described further in the “WHAT PERSONAL INFORMATION WE COLLECT” section of our Privacy Policy CHD is sourced from: (1) directly from you; (2) automatically through your use of the Services; and (3) other third-party sources, such as from other apps on your mobile device if you connect them with the Centr Services.

3. OUR PURPOSES FOR COLLECTING AND USING CONSUMER HEALTH DATA

As described further in the “WHY WE USE PERSONAL INFORMATION” section of our Privacy Policy, we process CHD (collect and use it) as reasonably necessary to provide Services you have requested or authorized. Many of the purposes for which we process data are, or could be, considered processing of CHD and can be categorized as follows:

• Providing, managing, maintaining and improving our Services and their features.

• Personalization and analytics associated with providing Services.

• Analytics, including research about how members utilize our Services to make improvements.

• Other essential business operations that support our Services (such as analyzing our business performance, ensuring security and integrity of our Services, conducting research and development).

• For quality assurance and training purposes.

4. CATEGORIES OF CONSUMER HEALTH DATA SHARED

We may share each of the categories of CHD described above in the “CATEGORIES OF CONSUMER HEALTH DATA WE COLLECT” section of this Policy. Specifically, we may share CHD with your consent or as reasonably necessary, to provide Services you have requested or authorized. For example, when you make a purchase, we will share information about the transaction as necessary to process the payment, including to protect against fraud. We may disclose CHD when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

For more information about categories of data processed by Centr, please see the “WHAT PERSONAL INFORMATION WE COLLECT” sections of our U.S. States Privacy Notice and Privacy Policy.

5. CATEGORIES OF THIRD PARTIES WE SHARE YOUR CONSUMER HEALTH DATA WITH

We may share CHD, with your consent or as reasonably necessary, to provide Services as described in the “OUR PURPOSES FOR COLLECTING AND USING CONSUMER HEALTH DATA” section of this Policy. These are the categories of third parties with whom we may share CHD:

• Centr Group Companies.We may enable access to CHD across our group companies, for example, where we share common data systems or where access helps us provide our Services. See the list of specific group companies in the “AFFILIATES WE MAY SHARE YOUR DATA WITH” section of this Policy.
• Service Providers. Vendors or agents (“processors”) working on our behalf may need access to CHD for the purposes described above. For example, vendors who provide IT services, analytics, payment processing, cloud storage, technical support, or delivery services.
• Third Party Apps & Accounts You Link with your Centr Account. As part of our Services, we enable you to connect your Centr account with third party applications. If you choose to connect your Centr account, we may share CHD with the paired application depending on what information you choose to share, or have otherwise been notified will be shared during the pairing process.
• Competent Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third Parties. We may disclose CHD to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process. In certain circumstances, it may be necessary to provide CHD to other third parties, for example, to comply with the law or to protect our rights or those of our customers, or to detect, prevent, or address security, fraud or technical issues.
• Parties to a corporate transaction (and their agents and advisors).We may disclose CHD as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

For more information about these categories of third parties, please see the “WHO WE SHARE YOUR PERSONAL INFORMATION WITH” section of our Privacy Policy and our U.S. States Privacy Notice.

6. AFFILIATES WE MAY SHARE YOUR CONSUMER HEALTH DATA WITH

The Centr affiliates we may share your CHD with are: Centr Holdings LLC (DE); Centr Management LLC (DE); Health in Motion (HIM) LLC (DE); CH Digital Pty Ltd (Australia).

7. HOW TO EXERCISE YOUR RIGHTS & HOW TO SET YOUR DATA PREFERENCES

Certain U.S. state Consumer Health Data privacy laws provide rights to Consumers, which may include, as applicable, rights to access, delete, or withdraw consent relating to such data, subject to legal limitations and exceptions. Please review the “YOUR RIGHTS AND PRIVACY PREFERENCES” section of our Privacy Policy for detailed information. If you would like to exercise any of your rights, including (in some states) a request to review and request changes to your CHD, please contact us at: privacy@centr.com.

If your request to exercise a right under applicable law is denied, you may appeal that decision by contacting us at privacy@centr.com. Please explain your concerns and provide the email associated with your account so we may properly review your data rights request history. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Attorney General of your state.

8. UPDATES TO THIS CONSUMER HEALTH DATA POLICY

We may update this Policy from time to time. When we do, we will provide notice of any material changes if and where this is required by applicable data protection laws. You can see when this CHDP was last updated by checking the "Effective Date" displayed at the top of this Policy.