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Consumer Health Data Privacy Policy

Effective: October 13, 2026

What changed on October 13, 2026: We added how we handle information from people who join the waitlist for our online community, The Collective (the community waitlist paragraph after the data table), and we now say “private call” instead of “discovery call.” Waitlist information is never sold or used for advertising. Nothing else changed.

What changed on October 2, 2026: We updated the introduction, added a row about genetic testing information to the table below, updated the sentence after it, and updated the section on third-party tracking, including a note about our third-party booking calendar. See also Genetic Testing and Genetic Data in our Privacy Policy.

The Vitality Collective LLC (“The Vitality Collective,” “we,” “us,” or “our”) is an online wellness and telehealth company based in Milford, Connecticut. We help adults in the states where our services are available access hormone replacement therapy, peptide therapy, and custom lab and blood panels through a network of independently licensed clinicians, and genetic testing through an independent testing company.

Because our services relate to your health, some of the information we handle is “consumer health data.” This Consumer Health Data Privacy Policy explains what consumer health data we collect, why we collect it, where it comes from, who we share it with, and how you can exercise your rights, including how to withdraw consent, request deletion, and appeal our decisions. It supplements our Privacy Policy, which describes our privacy practices more broadly.

Contents

Scope

This policy applies to “consumer health data” as defined by Washington’s My Health My Data Act (RCW Chapter 19.373), Nevada Senate Bill 370 (NRS Chapter 603A), Connecticut’s consumer health data provisions of the Connecticut Data Privacy Act, and similar state laws. As a matter of practice, we apply this policy to consumer health data about all of our users in the United States, wherever they live.

Consumer health data generally means personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. This policy does not apply to protected health information (“PHI”) governed by the Health Insurance Portability and Accountability Act (“HIPAA”), which is handled under the applicable Notice of Privacy Practices provided at or before intake. You can request a copy of that notice by contacting us at welcome@thevitalitycollective.co. This policy also does not apply to information that has been de-identified in accordance with applicable law.

Consumer health data we collect, why we collect it, where it comes from, and who we share it with

The table below lists each category of consumer health data we collect, the purposes for which we collect and use it, the sources from which we obtain it, and the categories of third parties with which we share it.

Category of consumer health data Purposes and how we use it Sources Categories of third parties we share it with
Health goals, symptoms, and health conditions you tell us about outside of clinical care (for example, when requesting a private call or contacting us) To respond to your questions; to schedule and hold private calls; to understand which of our services may fit your needs; and, if you choose to become a patient, to connect you with our clinical network You Service providers (processors); our clinical network, only if you choose to become a patient or request a consultation
Information about hormones, medications, bodily functions, or wellness that you choose to share with us Same purposes as the category above You Service providers (processors); our clinical network, only if you choose to become a patient or request a consultation
Your interest in, requests for, or purchases of health-related services, such as hormone replacement therapy, peptide therapy, genetic testing, or lab panels To provide the products and services you request; to process orders and payments; to provide customer support; to send transactional messages about your requests and orders; and to send marketing communications, only with your consent You; your interactions with our website and booking pages; our telehealth platform, pharmacy, and lab partners Service providers (processors); our clinical network; our telehealth platform, pharmacy, lab, and genetic testing partners; our payment processor, limited to the information needed to process your payment
Genetic testing information: that you bought a genetic test, your shipping address, and your genetic test consent records. We don’t keep your genetic report or raw DNA data (see Genetic Testing and Genetic Data). To process your order and payment; to send your name and shipping address to Genomic Dietetics & Performance Corp so your test kit can be sent and your test processed, only with your consent; to forward your report to you if the testing company sends it to us; to schedule your report walkthrough; and to keep a record of your consents You; Genomic Dietetics & Performance Corp, only if it sends your report to us. If it does, we forward it to you and delete our copy. Deleted copies are fully removed from our email systems within 30 days. Service providers (processors); Genomic Dietetics & Performance Corp (your name and shipping address only, with your consent); our payment processor, limited to the information needed to process your payment
Age and sex, when collected in connection with health-related services To understand your needs, provide the services you request, and connect you with our clinical network if you choose to become a patient You Service providers (processors); our clinical network; our telehealth platform, pharmacy, and lab partners
Information that identifies you as seeking health care services, such as requesting a private call, placing an order, or your order, subscription, or refill status To schedule calls and send booking reminders; to support your orders; to prevent fraud; and to calculate commissions owed to an affiliate or referral partner whose code or link you used (with your consent where required). Affiliates never receive your identity or any health information. You; our booking and scheduling tools; our telehealth platform, pharmacy, and lab partners Service providers (processors); our clinical network; our telehealth platform, pharmacy, and lab partners
Inferences about your health status drawn from the information above To respond to you and provide the services you request. We do not use these inferences for advertising. Derived from the information above Service providers (processors)

Community waitlist: your name, your email, and the fact that you joined the waitlist, used to confirm your spot and invite you to The Collective. It’s never sold or used for advertising.

Lab results ordered by a clinician in our clinical network are handled under the applicable Notice of Privacy Practices. Genetic testing is provided by Genomic Dietetics & Performance Corp, an independent company; see Genetic Testing and Genetic Data in our Privacy Policy for how genetic test information is handled.

Sources of consumer health data

  • Directly from you, through our forms, booking pages, calls, emails, and messages;
  • From your interactions with our website and booking pages;
  • From our clinical network and our telehealth, pharmacy, and lab partners, such as order and fulfillment status; and
  • From service providers that collect information on our behalf, such as our customer relationship management (CRM), marketing automation, and scheduling providers.

How we use consumer health data

We collect and use consumer health data only for the purposes described in the table above, which are:

  • To respond to your questions and requests;
  • To schedule and hold private calls and send booking reminders;
  • To provide the products and services you request and to connect you with our clinical network and partners when you choose to become a patient;
  • To process orders and payments and provide customer support;
  • To send transactional messages about the services you requested;
  • To send marketing communications, only with your consent;
  • To calculate affiliate and referral commissions without disclosing your identity or health information to affiliates, with your consent where required;
  • To protect the security of our services and prevent fraud; and
  • To comply with the law.

We do not use consumer health data for targeted advertising.

Categories of consumer health data we share and who we share it with

We share the categories of consumer health data listed in the table above only with the categories of third parties shown for each category. Those categories of third parties are:

  • Service providers (processors) that act on our behalf and under our instructions, such as our CRM, marketing automation, scheduling, website hosting, and email and text message delivery providers;
  • Our clinical network of independently licensed clinicians;
  • Our telehealth platform, pharmacy, lab, and genetic testing partners;
  • Our payment processor, limited to the information needed to process your payment;
  • Professional advisers, such as lawyers and accountants, when needed to provide advice to us;
  • Government authorities, courts, and others when required by law; and
  • A successor or acquirer in a merger, acquisition, or sale of all or part of our business, as permitted by law.

Affiliates. We do not currently share consumer health data with any affiliates (companies that control, are controlled by, or are under common control with The Vitality Collective LLC). If that changes, we will update this policy to list them.

What we do not do:

  • We do not sell consumer health data. We would never sell it without your valid signed authorization.
  • We do not share consumer health data with advertising platforms or use it for targeted advertising.
  • We do not share consumer health data with participants in our affiliate and referral program.
  • We do not use geofences around locations where health care services are provided to identify or track consumers, collect consumer health data, or send notifications or advertisements.

We collect consumer health data only with your consent or to the extent necessary to provide a product or service you have requested. We share consumer health data only with your separate consent or to the extent necessary to provide a product or service you have requested. When we ask for your consent, we will tell you what consumer health data we will collect or share, why, and with which categories of recipients, and how you can withdraw your consent. We will ask for your consent again before collecting, using, or sharing consumer health data for a purpose not described in this policy.

Third-party tracking on our website

Third-party analytics and advertising providers may collect information about your use of general pages of our website over time and across different websites and online services, as described in our Privacy Policy. We do not place advertising tools on pages where you book a call, check out, complete a medical intake, or access patient services, or on pages about specific treatments, and we configure our tools so that consumer health data is not sent to advertising platforms. We don’t currently use these tools on our Site. If we add them, they’ll run only with your consent. You can change your choices at any time by contacting us as described in our Privacy Policy or by adjusting your browser settings. If we add a cookie consent tool, we’ll add a “Cookie Settings” link to the Site footer.

Our online booking calendar is provided by a third-party scheduling platform. Its pages load a script from Meta even though we haven’t set up any Meta tracking on them, so Meta may receive basic technical information, such as your IP address and the page address, when you visit. We don’t send Meta your booking details or any health information.

How we protect and retain consumer health data

We limit access to consumer health data to employees, contractors, and service providers who need it to carry out the purposes described above and who are bound by confidentiality obligations. We require our processors to process consumer health data only under a written contract and according to our instructions. We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the data. We keep consumer health data only as long as needed for the purpose for which it was collected or as long as you consent, unless a longer period is required by law.

Your consumer health data rights

Subject to applicable law, you have the right to:

  • Confirm and access. Confirm whether we collect, share, or sell your consumer health data, and access that data, including a list of all third parties and affiliates with which we have shared or sold it and an active email address or other online way to contact each of them.
  • Withdraw consent. Withdraw your consent to our collection and sharing of your consumer health data.
  • Stop collection, sharing, or sale. Request that we stop collecting, sharing, or selling your consumer health data.
  • Delete. Request that we delete your consumer health data. We will delete it from our records and notify all processors, affiliates, and third parties with which we have shared it so they can delete it too. If the data is stored in archived or backup systems, deletion from those systems may take up to six months.
  • Review and request changes. Review the consumer health data we hold about you and request that we correct or change it.
  • Appeal. Appeal our decision if we decline to act on your request.

We will not discriminate against you for exercising any of these rights.

How to exercise your rights

You can submit a request by email or by mail:

  • Email: welcome@thevitalitycollective.co, with the subject line “Consumer Health Data Request”
  • Mail: The Vitality Collective LLC, Attn: Privacy, 364 Wheelers Farm Road, Unit 302, Milford, CT 06461

Please tell us your name, the email address and phone number you have used with us, your state of residence, and which right you want to exercise.

Verification. To protect your privacy, we will take commercially reasonable steps to verify your identity before acting on a request, usually by matching information you provide with information we already have. We will use information you provide for verification only for that purpose. If we cannot verify your identity, we will tell you and explain what else we need. Where the law allows, an authorized agent may submit a request on your behalf; we may ask the agent for proof of your signed permission and may ask you to verify your identity directly with us.

Timing and fees. We will respond within 45 days after we receive your request. If reasonably necessary, we may extend this period once by up to 45 additional days, and we will tell you about the extension and the reason for it within the first 45 days. We do not charge a fee for requests. If a request is manifestly unfounded, excessive, or repetitive, we may decline it where the law allows, and we will explain why.

How to withdraw your consent

You can withdraw your consent to our collection or sharing of your consumer health data at any time by emailing welcome@thevitalitycollective.co with the subject line “Withdraw Consent” or by writing to us at the mailing address above. You can also unsubscribe from marketing emails using the link in any email and stop text messages by replying STOP. After you withdraw consent, we will stop collecting and sharing your consumer health data for the purposes covered by that consent, except as needed to complete a service you have already requested or as required by law. Withdrawing consent does not affect processing that took place before you withdrew it.

How to appeal a decision

If we decline to act on your request, in whole or in part, you may appeal by replying to our response or by emailing welcome@thevitalitycollective.co with the subject line “Consumer Health Data Appeal” within a reasonable time after receiving our decision. You may also appeal by mail at the address above. We will respond to your appeal in writing within 45 days after we receive it, explaining any action taken or not taken and the reasons for our decision. If we deny your appeal, you may contact the Washington State Attorney General at atg.wa.gov/file-complaint, the Nevada Attorney General at ag.nv.gov, the Connecticut Attorney General at portal.ct.gov/ag, or the Attorney General in your state.

Changes to this policy

We may update this policy from time to time. When we do, we will post the updated version, change the effective date, and, for material changes, notify you before the changes take effect by posting a prominent notice on our website or by email. We will obtain your consent before collecting, using, or sharing consumer health data in a materially different way than described when we collected it.

Contact us

If you have questions about this Consumer Health Data Privacy Policy, please contact us by email or mail:

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