Consumer Health Data Policy

Categories and Uses of Consumer Health Data We Collect

Trenador only collects your Consumer Health Data as needed to provide the products or services you request or with your explicit consent.

Trenador may collect the following categories of Consumer Health Data:

• Individual health condition, treatment, disease, or diagnosis information;
• Social, psychological, behavioral, and medical intervention information;
• Health-related surgery or procedure information;
• Use or purchase of prescribed medication information;
• Bodily function, vital sign, symptoms, or measurement of health information;
• Diagnosis or diagnostic testing, treatment, or medication information;
• Biometric data;
• Information about your access to healthcare, including precise location information that could indicate an attempt to acquire or receive health services or supplies;
• Information processed to associate or identify an individual with the data listed above, derived or extrapolated from non-health information;
• Information about surgeries or other health-related procedures;
• Reproductive or sexual health information;
• Information about gender-affirming care;
• Information related to precise geo-location used to indicate an attempt to receive health care services or products; or
• Other information that may be used to infer or derive data related to the above or other consumer health data.

Trenador may process the categories of Consumer Health Data described above to the extent necessary to provide requested products or services, or with your consent, including:

• To enroll you in our programs and provide our products and services;
• To administer, manage, analyze, and improve our programs, products, and services;
• To analyze and better understand your needs, preferences, and interests, as well as those of other consumers;
• To conduct internal business analysis and market research;
• To monitor, investigate, and enforce compliance with our policies, terms and conditions, and legal and regulatory requirements;
• To comply with legal and regulatory obligations; or
• For our everyday business purposes.

Sources of Consumer Health Data

Trenador collects Consumer Health Data from the following sources:

• Directly from you, if you:
  • request health-related products and services;
  • register to use our health or wellness-related apps;
  • join our email lists or loyalty programs; or
  • volunteer the information in our app or in connection with surveys or promotions.
• Indirectly from you (gathered through social media, other websites, or apps) if you:
  • interact with us by using our apps or accessing our systems;
  • enable certain mobile app functions, such as location tracking; or
  • like, follow, or comment about health-related products on our social media sites.
• From our vendors, suppliers, consultants, professional advisers, and other third parties when business contact information, financial information, and other data are necessary to operate our business.
• Health insurance companies or other payors, when:
  • Information is necessary to provide our products and services;
  • Information is necessary to determine program eligibility; or
  • Information is necessary to comply with legal and regulatory obligations.
• Your authorized legal representative, family members, or caregivers.

Why We Collect and Use Consumer Health Data

We collect and use Consumer Health Data for the purposes described in the "Personal Information We Collect" and "How We Use Your Personal Information" sections of our Privacy Policy. We primarily collect and use Consumer Health Data as reasonably necessary to provide the products or Services you have requested or authorized. This includes delivering and operating products and Services, personalizing features, ensuring secure and reliable operation, troubleshooting and improving products and Services, and supporting other essential business operations. We may also use Consumer Health Data for other purposes for which we give you choices and obtain your consent as required by law.

How We May Share Consumer Health Data

Trenador only shares or discloses your Consumer Health Data as needed to provide the products or services you request or with your explicit consent. We may share any of the above categories with the following entities, who may use the data only as permitted for the purposes above and within the bounds of our contracts:

• Business collaborators;
• Product co-promotion partners;
• Product co-development partners;
• Marketing and advertising agencies;
• Social media companies and platforms;
• Service providers, including those hosting or analyzing data, assisting with fraud prevention, program administration, or information technology and security;
• Emergency personnel;
• Authorized legal representatives, family members, and caregivers;
• Third parties, including those with whom Trenador has joint marketing or similar arrangements, those who provide marketing and analytics services, those who provide program enrollment, product fulfillment, payment, and authorization, and others as necessary to complete transactions or comply with law;
• Trenador lawyers, auditors, and consultants; or
• Legal and regulatory bodies.

In addition, we may share or disclose Consumer Health Data as permitted or required by law, such as: (i) to an acquiring organization if we are involved in a sale or transfer of our business; (ii) to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities; (iii) in situations involving violations of our terms of use or other rules; (iv) to protect our rights and the rights and safety of others; (v) to support external auditing, compliance, and corporate governance; (vi) to preserve the integrity or security of our systems; or (vii) to investigate, report, or prosecute illegal activity under applicable law.

Your Consumer Health Data Privacy Rights

Subject to legal limitations and exceptions, you have the following rights with respect to Consumer Health Data we may collect about you:

• To confirm whether we are collecting, sharing, or selling your Consumer Health Data;
• To access such data, including a list of affiliates or specific third parties with whom we have shared or sold your information, along with contact information such as an email address for each third party;
• To review and request corrections to your Consumer Health Data;
• To withdraw consent from our collection or sharing of your Consumer Health Data; and
• To request that we delete your Consumer Health Data.

You may submit a request by contacting us at support@trenador.com.

Trenador will not discriminate against you for exercising your rights. We will respond to requests promptly in accordance with applicable laws. Please allow 45 days for a response. We may request additional information to authenticate your request and verify your identity. We may be unable to fulfill these rights in certain circumstances, such as when legally prevented.

If we deny your request, you may appeal by contacting us at support@trenador.com. We will respond to your appeal within the time permitted by law. If you are a Washington resident and your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Changes to Our Consumer Health Data Policy

We may update this Consumer Health Data Policy from time to time. We will make the updated statement available on this page. We intend to use Consumer Health Data in accordance with the policy in place at the time the data was collected.

Nevada Supplemental Consumer Health Data Privacy Notice

This Supplement applies to Nevada consumers and provides additional disclosures required by Nevada's Consumer Health Data Privacy Law. We collect, use, process, and share Consumer Health Data for the purposes and manners described in this Consumer Health Data Policy.

Third Party Collection of Consumer Health Data on Trenador Websites. We limit third-party collection of Consumer Health Data over time and across different Internet websites or online services when Nevada consumers use our websites or online services. We do this by disabling certain cookies or by ensuring that entities whose cookies, web beacons, pixels, and other trackers we use are our service providers or processors under applicable law. Please note that other third parties may still be able to process Consumer Health Data from you over time and across different websites depending on your browser, browser settings, add-ons, and device permissions. This collection is unrelated to Trenador's processing of Consumer Health Data, and we encourage you to review your browser settings and those third parties' privacy notices for more information.

Review and Revision of Consumer Health Data. If you would like to review and/or revise your Consumer Health Data, you may submit a request using any method listed in this Notice.