Introduction & Scope

This Notice supplements the Denon Maximchuk Privacy Policy for residents of Washington and Nevada. It explains what we consider Consumer Health Data, what we collect, how we use and share it, your rights, and how to contact us. If any term in this Notice conflicts with our Privacy Policy, this Notice controls for Washington and Nevada residents as to Consumer Health Data. Washington’s My Health My Data Act and Nevada’s SB 370 require disclosures, consent, and rights specific to Consumer Health Data.

What is Consumer Health Data and What Counts as Consumer Health data

Consumer Health Data means personal information that identifies or could reasonably be linked to you and that reveals or is used to infer your past, present, or future physical or mental health status. Examples include information about mental health, emotions, relationship or sexual life that you choose to discuss in coaching, health conditions or symptoms, testing or assessment responses and results, treatment or program recommendations, appointment information, and inferences drawn from these categories. Audio or video recordings, call transcripts, and AI summaries may contain Consumer Health Data. This definition follows Washington and Nevada law and is broader than HIPAA.

Categories of Consumer Health Data We Collect

a. Coaching content you share and our coaching notes.
b. Call recordings, transcripts, and AI summaries when you consent to recording.
c. Assessments, questionnaires, and testing responses, including derived insights.
d. Scheduling and engagement information such as appointment date and time and attendance.
e. Emails, SMS, chat messages, and form submissions that include health-related content.
f. Inferences we derive to tailor coaching such as observed attachment patterns or regulation strategies.

Sources of Consumer Health Data

a. Directly from you through intake forms, calls, messages, and assessments.
b. From enabled recording, transcription, and summarization tools.
c. From our coaches through observations and internal notes created while delivering services.

How We Use Consumer Health Data

a. Deliver and improve coaching services you request, maintain your client file, and support continuity if more than one coach is assigned.
b. Quality assurance, training and supervision, and human-reviewed AI summaries that support internal workflow.
c. Internal research and product development, including creation of de-identified or aggregate insights that do not identify you.
d. Security, fraud prevention, and compliance with law.
e. Establish, exercise, or defend legal claims or comply with mandatory reporting.
We use Consumer Health Data only as reasonably necessary and proportionate to these purposes. If we later want to use Consumer Health Data for a new purpose, we will obtain fresh consent where required.

Processing Activities

We may collect, record, transcribe, summarize, store, view, analyze, de-identify, aggregate, transmit to processors, and delete Consumer Health Data. We will delete or de-identify data when no longer needed for the purposes stated in this Notice or our Privacy Policy.

How We Share Consumer Health Data

We do not sell Consumer Health Data. We share only as follows.
a. Processors. We use contracted service providers that handle video meetings, transcription and AI summarization, secure cloud storage, CRM and ticketing, email and SMS delivery, IT security and monitoring, and analytics used to support service quality. Processors may only process Consumer Health Data under our instructions and may not use it for their own purposes. Washington and Nevada require a written contract with processors that limits processing to the services we request.
b. Your direction or consent. For example, if you ask us to share information with a therapist or partner.
c. Legal. Courts, regulators, or law enforcement if required by law, or when necessary to establish, exercise, or defend legal claims.
d. Corporate events. In a reorganization or sale, with equal or stronger protections.

Advertising and Tracking Technologies

We do not intentionally transmit Consumer Health Data to advertising or marketing tags. We block advertising and analytics tags on pages and forms that collect health or relationship content and we use technical measures to prevent this data from being sent in URLs, events, or free text fields. If we learn that a tag collected Consumer Health Data, we will request deletion and remediate. These practices reflect recent guidance and enforcement risks related to tracking technologies.

Consent for Washington and Nevada Residents

For Washington and Nevada residents, we obtain separate, affirmative opt-in consent to collect Consumer Health Data and separate, affirmative opt-in consent to share Consumer Health Data with processors, unless a legal exception applies. Consent may be captured at the start of a recorded call, through website or form checkboxes, or inside our services. You may withdraw consent at any time as described in Section 12. Nevada and Washington require separate and distinct consents for collection and for sharing.

Geofencing

We do not use geofencing to identify or track people seeking health care services, to collect Consumer Health Data, or to send notifications or advertisements related to Consumer Health Data around health care facilities. Washington and Nevada prohibit geofencing for certain health-related purposes.

Data Security
We use administrative, technical, and physical safeguards that are appropriate to the sensitivity of Consumer Health Data. These measures include encryption in transit and at rest where applicable, role-based access, least-privilege permissions, vendor contracts, and monitoring and incident response.

Your Rights for Washington and Nevada

You may submit the following requests.

a. Confirm whether we collect or process your Consumer Health Data.
b. Access your Consumer Health Data and obtain a list of third parties and affiliates with whom we have shared it.
c. Withdraw consent to collection and or sharing.
d. Request deletion of your Consumer Health Data.
We will respond within the timelines required by law and will verify your identity and, if you use an authorized agent, their authority. If we deny your request, you may appeal and we will explain the outcome and how to contact your state regulator.

Retention

We retain Consumer Health Data only as long as reasonably necessary for the purposes in this Notice and our Privacy Policy, then delete or de-identify it consistent with those policies and legal requirements.

De-identified and Aggregate Data

We create de-identified and aggregate data using reasonable methods, maintain safeguards to prevent re-identification, and do not re-identify de-identified data.

How to Exercise Your Rights

Email [email protected] with the subject line “WA NV CHD Request” and tell us which rights you want to exercise. To appeal a decision, reply to our response with the subject line “Appeal.”

Charges to This Notice

We may update this Notice to reflect changes in our practices or in state law. We will post the updated date at the top of this page. Significant changes will be highlighted on our site or sent to you through our services.