1. Purpose and Scope
Effective Date: October 5, 2025
This Consumer Health Data & Biometric Privacy Policy ("Policy") is issued by Healsend Inc. ("Healsend"), a Management Services Organization (MSO) and technology facilitator. Healsend is not a medical provider, does not practice medicine, and does not independently function as a HIPAA-covered entity. The Professional Entities supported by Healsend's Platform are independent licensed healthcare providers who may be covered entities or business associates under HIPAA.
This Policy covers Consumer Health Data (CHD) and biometric data collected and processed by Healsend in its capacity as a technology platform and data controller — separate from PHI processed by Professional Entities under their own Notices of Privacy Practices and HIPAA Business Associate Agreements. This Policy supplements our Master Privacy Policy.
2. Definitions
- Consumer Health Data (CHD): Personal information that identifies your past, present, or future physical or mental health status, including diagnoses, medications, health conditions, health-related payments, bodily functions, or characteristics regulated under WA MHMDA, NV SB370, or similar state laws.
- Biometric Data: Data generated from physiological or behavioral characteristics used for identification, including fingerprints, voiceprints, iris scans, retinal scans, face geometry, and gait patterns.
- Sensitive Health Data: A subset of CHD that includes reproductive and sexual health information, mental health status, substance use disorder information, and genetic data.
- Personal Information: Information that identifies, relates to, or could reasonably be linked to an individual or household.
- Professional Entity: Independent licensed physician groups, professional corporations, or PLLCs that use the Platform to deliver clinical care.
- Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
- Service Provider/Contractor: Entities that process data on Healsend's behalf under contracts restricting them to performing services for us.
- De-identified Data: Information from which all direct and reasonably linkable identifiers have been removed under HIPAA Expert Determination or Safe Harbor methods.
- Business Associate: Healsend, in its capacity as a BA under 45 CFR §160.103, when processing PHI on behalf of a covered Professional Entity under a signed BAA.
- Consumer Request: A verifiable request from you to exercise a privacy right listed in Section 8.