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CONSUMER HEALTH DATA PRIVACY POLICY

ASANTE HEALTH, INC.

Effective Date: July 14, 2026   |   Version: 1.0

This Consumer Health Data Privacy Policy (“CHD Policy”) describes how Asante Health, Inc. (“Asante Health,” “we,” “us,” or “our”) collects, uses, and shares “consumer health data,” and the rights you have, under the Washington My Health My Data Act, the Nevada consumer health data law, the Connecticut Data Privacy Act, and similar state laws. This CHD Policy supplements our general Privacy Policy. If there is a conflict regarding consumer health data, this CHD Policy controls.

1. What Is Consumer Health Data

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 status. For our Services, this can include information about your conditions, surgeries and recovery, symptoms, treatments, the surgical readiness indicator, nutrition and dietary data, sleep data, activity and biometric data from connected devices, and any health information you provide.

2. Categories of Consumer Health Data We Collect

  • Health conditions, surgical history, and recovery and rehabilitation information;
  • Information used to generate or derived from the surgical readiness indicator;
  • Activity, exercise, and biometric data from connected wearables or sources;
  • Nutrition, dietary, and sleep information;
  • Symptoms, goals, and self-reported health status; and
  • Inferences we draw from the above to provide coaching and educational content.

3. Sources of Consumer Health Data

We collect consumer health data directly from you, automatically from your use of the Services, from devices and third-party health data sources you connect, and, if you opt in, from your Care Team.

4. How We Use Consumer Health Data

We use consumer health data to provide and personalize the Services; to generate educational content, coaching, and the surgical readiness indicator; to enable Care Team connection if you opt in; to maintain safety, security, and quality; to conduct research and product development and to train and improve our models in de-identified form; and to comply with law. We collect and use consumer health data only as necessary for these purposes and only with your consent where required by law.

5. How We Share Consumer Health Data

We may share consumer health data with the following categories of recipients:

  • Service providers and processors that process consumer health data on our behalf under contracts requiring confidentiality, security, and use limited to our instructions;
  • Your Care Team where you opt in and authorize sharing;
  • Affiliates that operate under this CHD Policy;
  • Legal and safety recipients where required by law or to protect rights and safety; and
  • A successor in a merger, financing, acquisition, or asset sale, subject to this CHD Policy.

The specific affiliates with whom we share consumer health data are: none 

6.  We Do Not Sell Consumer Health Data; No Geofencing

We do not sell your consumer health data. We will not sell your consumer health data without first obtaining your valid, written authorization that meets the specific requirements of applicable law, separate from your consent to collection. If our practices ever change, we will update this CHD Policy and obtain any authorization required before any sale. We also do not use geofencing around facilities that provide in-person health care services to identify or track you, to collect your consumer health data, or to send you notifications, messages, or advertisements related to your consumer health data or health services.

7. Consent to Collection and Sharing

We collect consumer health data that is not necessary to provide a product or service you requested only with your consent, and we share consumer health data beyond what is necessary to provide the Services only with your consent or as otherwise permitted by law. We obtain your consent before collecting or sharing consumer health data where required, and consent is requested separately from other terms.

8. Your Rights

Subject to applicable law, you have the right to:

  • Confirm whether we are collecting, sharing, or selling your consumer health data and access that data;
  • Obtain a list of the third parties and affiliates with whom we have shared your consumer health data;
  • Withdraw your consent to our collection and sharing of your consumer health data;
  • Have your consumer health data deleted; and
  • Appeal a refusal to act on your request.

We will not discriminate against you for exercising these rights. When you ask us to delete consumer health data, we will delete it from our records, including from backups and archives within the time allowed by applicable law, and notify our processors and affiliates to do the same, except where retention is permitted or required by law.

9. How to Exercise Your Rights

You can submit a request by email or through the in-app privacy controls. We will verify your request and respond within the time required by law. To appeal, reply to our decision or contact our Privacy Officer. If your appeal is denied, we will provide you with information about how to contact your state attorney general to submit a complaint.

Requests and appeals: CHD@asantehealthy.com 

10. Security

We maintain administrative, technical, and physical safeguards designed to protect consumer health data, as described in our general Privacy Policy.

11. Changes and Contact

We will post any updates to this CHD Policy with a new Effective Date and provide notice of material changes. To contact us about consumer health data:

Asante Health, Inc., Attn: Privacy Officer 

CHD@asantehealthy.com