Washington Consumer Health Data Privacy Notice

Effective Date: 7/2/2026 Last Updated: 7/2/2026

This notice is provided in accordance with the Washington My Health My Data Act (RCW 19.373) (“MHMDA”) and applies to residents of Washington State (and, per the Act, any individual whose consumer health data is collected in Washington). It supplements our general Privacy Policy and describes specifically how we handle Consumer Health Data.

1. What Is “Consumer Health Data” Under This Notice

Under MHMDA, “Consumer Health Data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. This can include information related to health conditions, diagnoses, symptoms, or similar information — even if you only mention it briefly in a chat conversation and even if we do not save it. MHMDA defines “collect” broadly to include processing such data, not just storing it.

Because our Chat Assistant does not ask for medical information but may receive it if you volunteer it, any such information you choose to type into the Chat Assistant may qualify as Consumer Health Data under this law for the brief period it is processed.

2. Categories of Consumer Health Data We May Process

We do not solicit health information. However, if voluntarily provided by you through the Chat Assistant, we may momentarily process:

  • References to medical conditions, diagnoses, or symptoms
  • References to prescriptions, treatments, or healthcare providers
  • Any other statement reasonably interpreted as relating to your physical or mental health status

We do not collect biometric data, precise location data tied to health facilities, or reproductive/gender-affirming care data as a matter of course, unless you independently choose to volunteer such information in the chat.

3. Sources of Consumer Health Data

The only source of Consumer Health Data we process is you, directly, through voluntary input into the Chat Assistant. We do not purchase, license, or obtain Consumer Health Data about you from data brokers or other third parties.

4. Purpose of Processing

Any Consumer Health Data you provide is processed solely to:

  • Generate real-time, session-specific health share plan recommendations

We do not use Consumer Health Data for advertising, analytics profiling, employee/employer decision-making, or any purpose beyond generating your immediate recommendation.

5. No Storage / Retention

As described in our general Privacy Policy, we do not retain Consumer Health Data after your session ends. It is processed transiently to generate your recommendation and is not saved in any database, log, or file accessible to us after your session concludes — including no storage in a customer relationship management (CRM) system or marketing database — except to the limited extent temporarily necessary for SiteGPT, our AI processing provider, to return a response (see Section 6).

6. Categories of Third Parties and Affiliates We Share Consumer Health Data With

We share Consumer Health Data with the following categories of third parties, only as necessary to operate the Chat Assistant:

  • AI processing provider: SiteGPT. Your chat input, including any voluntarily-shared Consumer Health Data, is transmitted to SiteGPT to generate a response. SiteGPT may briefly process this data on their infrastructure in order to return a response to you, subject to their own data handling terms. We select providers that contractually restrict them from using your inputs to train their models or retain them beyond what’s needed to deliver the service, but we encourage you to review SiteGPT’s own privacy policy at https://sitegpt.ai/security for details on their processing.
  • Health share plan providers: Only if you affirmatively click through and choose to share information directly with a specific provider — at that point, you are interacting with their systems under their own privacy practices, not ours.

We do not sell Consumer Health Data. We do not share Consumer Health Data with data brokers, advertisers, or for cross-context behavioral advertising.

7. Your Rights Under Washington My Health My Data Act

If you are a Washington resident (or your Consumer Health Data was collected while you were in Washington), you have the right to:

  • Confirm whether we are processing your Consumer Health Data
  • Access your Consumer Health Data (including a list of third parties it has been shared with)
  • Withdraw consent to our collection or sharing of your Consumer Health Data
  • Delete your Consumer Health Data
  • Appeal a denial of any of the above requests

Because we do not retain Consumer Health Data after your session, in most cases there will be nothing on file to access or delete beyond what you may have separately submitted (e.g., a ontact form). We will still process and respond to all rights requests as required by law.

To exercise these rights, contact us at: info@smartshare.health

We will respond within the timeframe required by law and will not discriminate against you for exercising these rights. If we deny your request, you may contact the Washington Attorney General.

Where MHMDA requires your consent before we collect or share Consumer Health Data, we will obtain that consent through a clear affirmative action (e.g., a checkbox or acknowledgment) before such processing occurs, separate from acceptance of our general Terms of Use or Privacy Policy.

9. Geofencing Restriction

Consistent with MHMDA, we do not implement geofencing technology around any in-person healthcare facility (e.g., to identify or track consumers seeking healthcare services, or to send them targeted messages, or to infer health status based on their visit).

10. Changes to This Notice

We may update this notice from time to time. Material changes will be reflected in the “Last Updated” date above and, where required, communicated through additional notice.

11. Contact Us

Smart Share info@smartshare.health