META FLOW LTD.

Consumer Health Data Privacy Policy

Last Revised: 2024-09-03 08:59:52

This Privacy Policy (“Policy”) supplements our General Privacy Policy and explains how we collect, use and disclose personal information that falls within the definition of Consumer Health Data under applicable U.S. state laws including Washington's My Health My Data Act and Nevada's Consumer Health Data Privacy Law.

The term “Consumer Health Data” in this Policy, means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status, as defined by Washington's My Health My Data Act and Nevada's Consumer Health Data Privacy Law. Consumer Health Data does not include, among other things, data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our General Privacy Policy.

1. Categories of Consumer Health Data We Collect

We may collect the following categories of Consumer Health Data:

  • Individual health condition, including information about your bodily functions, diseases, symptoms, status, diagnoses, testing, treatments or measurements such as:
    • Your physical objective and/or subjective state and nutrition data, including height, weight, sleep habits, food, caffeine and water intake, heart rate, breath data, perceived sense of viability, real-time assessment of carbohydrate availability and metabolic fuel use as measured via use of the Lumen Device and through the Lumen App or Website.
    • Information regarding your health-related habits such as daily diet, exercise routine as well as ongoing feedbacks that you provide us regarding your ‎satisfaction from the health habits, the difficulty to follow-up with the ‎habits, etc.
    • Body activity data, such as types of exercise, number of steps, speed and distance.
    • Self-reported Information about physiological, behavioral, and ‎biological characteristics‎.
  • Data that identifies a consumer seeking health care services. for instance, if your Lumen Device was provided to you by your healthcare provider or clinic, we will collect the fact that you received healthcare services from that specific healthcare provider or clinic.
  • Information we may collect via automated means or derive about you, which could include any information that we, or one of our processors, processes to associate or identify you with the data described above that is derived or extrapolated from non- health information. Such information may include your device and browser information, activities and usage data about your use of our Services, location information derived from your IP address or your mobile device, your online activity through cookies and similar technologies.
  • Any other Consumer Health Data you choose to share with us, including, but not limited to, information about health-related surgeries or procedures, and biometric data.

2. How We Use Consumer Health Data

We collect, use and disclose Consumer Health Data as reasonably necessary to provide you with the products and services you have requested. This may include:

  • Providing, operating and improving our Services;
  • Personalizing the Services and content provided to you, customizing and improving your use experience of the Services;
  • Studying and analyzing the information on an aggregated, statistical basis to discover patterns and anomalies, to study complications and treatment methods and improvements, and other health related research and development;
  • Sending you updates, notices, notifications, and additional communications regarding the Services;
  • Complying with any applicable rule or regulation, protecting our legal interests and/or responding to or defending against (actual or potential) legal proceedings against us or our affiliates.

We may also collect, use and disclose Consumer Health Data for other purposes with your consent or authorization or as otherwise permitted by law.

3. Sources from which We Collect Consumer Health Data

We may collect Consumer Health Data in the following ways:

  • Directly from you such as when you actively and voluntarily provide us with Consumer Health Data through our mobile app or Website;
  • Your Lumen Device when using it;
  • Your mobile device and web browser when accessing our mobile app or Website such as when you view content that could indicate your health condition. This may include collection of Consumer Health Data over time and across our Services. For more information about this, please see our "Cookies" section in our General Privacy Policy;
  • Your other third-party apps or other third-party services with which you have integrated or linked your Lumen account (such as Apple Health Kit, Android Fit, etc.);
  • Your healthcare providers, care management services, or healthcare payers, to the extent your relationship with us originates from one of them.
  • Drawn from other information we collect. Depending on your use of our Services, we may also draw inferences from the information we collect, such as your preferences, characteristics, attributes, and abilities.

4. Sharing of Consumer Health Data

We may share each of the categories of the Consumer Health Data described above we collect about you with third parties when reasonably necessary to achieve the purposes and uses listed above. The categories of third parties we share your consumer health data with are:

  • Service providers. We are partnering with several selected service providers, whose services and solutions complement, facilitate and enhance our own. Such third-party service providers may have access to, or process information on our behalf, including Consumer Health Data.
  • Your known health care providers, care management services or healthcare payers. To the extent your relationship with us originates from one of them, we may provide your Consumer Health Data to that party for its use in connection to the services it provides to you.
  • Our Affiliated Companies. We may share your Consumer Health Data with the following entities in our group: Lumen, Inc.
  • Auditors and advisers. we share your data with our external auditors, advisors and professional ‎service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our ‎compliance with regulatory requirements and industry standards, auditing, ‎managing disputed etc.
  • Business transfer. If we are involved in a merger, ‎acquisition, asset sale, reorganization or other corporate combination, ‎your Consumer Health Data may be transferred to the ‎acquiring or surviving entity.
  • Law enforcement, legal proceedings, and as authorized by law. We may disclose Consumer Health Data to satisfy any applicable law, regulation, legal process, subpoena or governmental request.
  • We also may permit third parties to collect Consumer Health Data over time on our websites and mobile services, and across other participating websites and mobile services.

5. How to Exercise Your Rights Regarding Consumer Health Data

Depending on where you live and subject to certain exceptions, you may have certain rights related to your Consumer Health Data. This includes the right to:

  • Request that we confirm whether we are collecting or disclosing your Consumer Health Data (and with whom);
  • Request access to your Consumer Health Data;
  • Request deletion of your Consumer Health Data;
  • Request withdrawal of your consent for the collection and sharing of your Consumer Health Data.

You can exercise your rights with respect to your Consumer Health Data, by sending us an email at support@lumen.me or by writing to the address below:

Meta Flow Ltd.
Address: 30 Ha’arba’a Street, Tel Aviv, Israel

We will respond to your request as required by applicable law. When you submit a request regarding your Consumer Health Data, we reserve the right to verify your identity to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information.

If your request to exercise a right is denied, you may appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to support@lumen.me.

If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable attorney general:

6. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Effective Date” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.