Consumer Health Data Privacy Policy
Oser Clair LLC · Effective [DATE POSTED]
This policy explains how Oser Clair LLC ("Osér Clair", "we" or "us") collects, uses and shares consumer health data, and how you can exercise your rights. It is written to meet Washington's My Health My Data Act and Nevada's consumer health data law, and we apply it to everyone, wherever you live.
1. Consumer health data we collect, and why
1.1 Consumer health data is personal information that is linked or reasonably linkable to you and that identifies your past, present or future physical or mental health. It includes information inferred from other data, such as a purchase.
| Category | What it includes | Why we collect it and how we use it |
|---|---|---|
| Library purchases | Your name, email address, the Condition Dossier you bought and the date. A dossier's topic can suggest something about your health, so we treat this as consumer health data. | To deliver the dossier, send you new versions you request during your update period, answer your messages and keep tax records |
| Client information | Your health questions and goals, the diagnosis and history you report to us, documents and records you choose to share in your shared folder, and what you tell us on calls and in messages | To provide the research, coaching and support you asked for under your signed agreement, and to keep the records that agreement describes |
| Call recordings, transcripts and summaries | Recordings and notes of client meetings, made only if you've agreed to recording | So we can listen rather than type, and to prepare your deliverables. You can withdraw that consent for any meeting. |
| Applications and messages | Anything health-related you include in a no-charge place application, a website form or an email, even though we ask you not to | To respond to you and, for applications, to run the random draw. Health details play no part in who is drawn. |
1.2 We don't collect consumer health data through site statistics or cookies. Visits to Library pages are counted only in aggregate and aren't linked to you, and those pages carry no advertising or tracking pixels.
2. Where it comes from
2.1 We collect consumer health data directly from you: at checkout, through forms and email, through your shared folder, and on calls. We don't buy health data, we don't collect it from data brokers, and we don't request your records from your healthcare providers. If you share records you obtained yourself, they come to us from you.
3. Consent
3.1 We collect and use consumer health data only as necessary to provide the product or service you've asked for, or with your consent.
3.2 We share it only as described in section 4. Before we share it for any other purpose, collect a new category of it, or use it for a new purpose, we'll update this policy and ask for your separate consent.
4. Who we share it with
4.1 We share the categories of consumer health data in section 1 only with processors, which are service providers that handle it on our behalf, under contract, and only for the purposes in section 1:
| Type of processor | Consumer health data it handles |
|---|---|
| Payments and sales tax (Stripe) | Library purchases |
| Website hosting, database and file delivery (Lovable, and the infrastructure it runs on) | Library purchases, and form and application submissions |
| Email, file storage, calendar and video calls (Google Workspace) | All categories, as each purpose needs |
| Meeting recording and transcription | Call recordings, transcripts and summaries, only if you've agreed to recording |
| AI research and writing tools | Minimized summaries of a client's research questions, identified by file number only and never by name or contact details |
4.2 We have no affiliates. We don't share consumer health data with any third party other than these processors, except when the law requires us to, such as to respond to a valid court order.
4.3 We don't sell consumer health data, and we don't use it for advertising.
5. Your rights
5.1 You have the right to:
- confirm whether we collect, share or sell your consumer health data;
- access it, including a list of every third party and affiliate we've shared it with or sold it to, and their contact details;
- withdraw your consent to our collecting and sharing it;
- have it deleted. We'll delete it from our records and tell our processors to delete it too. Copies in backups are deleted within 6 months.
5.2 If you live in Nevada, you also have the right to ask us to stop collecting, sharing or selling your consumer health data.
5.3 Using these rights is free up to twice in any 12-month period, and we won't treat you differently for using them. If the law requires us to keep some information, such as tax records of a purchase, we'll tell you what we kept and why.
6. How to make a request
6.1 Email lola@oserclair.com with the subject line "Health data request" and tell us which right you're using. Please write from the email address you used with us, so we can confirm it's you. If we can't confirm your identity that way, we'll ask for the least extra information we need.
6.2 We'll respond within 45 days of receiving your request. If we need more time, we may extend that once, by up to 45 more days, and we'll tell you why within the first 45.
7. How to appeal
7.1 If we decline your request, in whole or in part, you can appeal by replying to our decision with the word "Appeal". We'll tell you in writing what we decided and why within 45 days of receiving your appeal.
7.2 If we deny your appeal, you can file a complaint with the Washington State Attorney General or, if you live in Nevada, the Nevada Attorney General's Office.
8. Changes to this policy
8.1 The date at the top shows when this version took effect. We won't collect new categories of consumer health data, or use or share it for new purposes, until we've updated this policy and you've consented.
9. Contact us
Questions about this document go to lola@oserclair.com.
Oser Clair LLC · 2501 Chatham Rd #5095, Springfield, IL 62704