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Consumer Health Data Privacy Policy

Last Updated: Mar 31, 2024

This Consumer Health Data Privacy Policy supplements the Ro Privacy Policy (the “Privacy Policy”) and applies to personal data defined as “consumer health data” (“CHD”) by the Washington state My Health My Data Act (“MHMDA”) and Nevada’s Consumer Health Data Privacy Law (“Nevada CHD Law”). Undefined capitalized terms shall have the meaning in the Privacy Policy.

Categories of CHD Collected

As described further in our Privacy Policy, and depending on how you interact with Ro and applicable law, we may collect the following categories of CHD, as broadly defined in the MHMDA and Nevada CHD Law:

  • Individual health conditions, treatment, diseases, or diagnoses: E.g. in connection with you seeking healthcare services or medications from Ro.

  • Social, psychological, behavioral, and medical interventions: E.g. through collection of your medical history as part of the treatment services you seek on or through Ro.

  • Health-related surgeries or procedures: E.g. through collection of health-related surgeries or procedures within your medical history as part of the treatment services you seek on or through Ro.

  • Use or purchase of prescribed medication: E.g. through your purchase of medication through Ro or through the medical history you provide to us.

  • Bodily functions, vital signs, symptoms, or measurements of health information: E.g. as part of you seeking healthcare services or medications from Ro.

  • Diagnoses or diagnostic testing, treatment, or medication: E.g. as part of the medical history collected by Ro, or when you otherwise seek healthcare services or medications from Ro.

  • Gender-affirming care information: E.g. as part of the medical history collected by Ro, or when you otherwise seek healthcare services or medications from Ro.

  • Reproductive or sexual health information: E.g. as part of the medical history collected by Ro, or when you otherwise seek healthcare services or medications from Ro.

  • Genetic data: E.g. where such information is included in medical history collected by Ro.

  • Data that identifies a consumer seeking health care services: E.g. as part of the medical history collected by Ro, or when you otherwise seek healthcare services or medications from Ro.

  • Other information that may be used to infer, derive, or extrapolate data related to the above or other health information.

Sources of CHD

As described further in our Privacy Policy, we collect information, which may include CHD from the following sources: (1) directly from you; (2) automatically through your use of the Services; (3) social media and other content platforms; and (4) other third-party sources.

Purposes for Collection of CHD

We describe the purposes for collection and use of CHD in the “Purposes for How We Use Your Information” section of our Privacy Policy. As further described there and subject to applicable law, we may collect and use CHD as directed by you or with your consent, or (1) to provide and manage the Services; (2) to analyze and improve the Services; (3) for advertising and marketing; and (4) for legal purposes, such as to comply with laws or to establish, exercise, or defend our legal rights.

How and Why We Share CHD

We may share each of the categories of CHD described above for business purposes to the categories of entities described in the “How We Disclose Your Information” section of our Privacy Policy. As further described in our Privacy Policy and subject to applicable law, we may share the categories of CHD:

  • to deliver products and services to you, including to complete any transactions initiated by you;

  • to ensure a consistent level of service across our products and services; 

  • to enhance our products, services, and your customer experience;

  • with your consent, such as disclosures for certain advertising or promotional efforts, including allowing third parties to collect CHD across our Websites;

  • to protect Ro and others, including to enforce our Terms of Use, Privacy Policy, or other contracts with you, and for fraud prevention;

  • to comply with our legal obligations; and

  • in connection with any negotiation or completed acquisition, merger, or purchase involving our business assets.

As described in our Privacy Policy, we reserve the right to create Aggregate/De-Identified Data from the information we collect through the Services and our disclosure of such Aggregate/De-Identified Data is in our discretion.

As further described in our Privacy Policy, and subject to applicable law (e.g. subject to your consent in certain situations), we may share CHD with the following categories of third parties and affiliates:

  • Health Care Providers and Services;

  • Service Providers;

  • Advertising Networks;

  • Joint Product/Marketing Partners;

  • For the Protection of Ro and Others (e.g. to governmental or regulatory agencies);

  • For Legal Purposes (e.g. to governmental entities in response to legal process);

  • As Necessary for Business Transfers; 

  • At Your Direction or With Your Consent (such as sharing with other users/public if you post in public forums or interact with other users); and

  • With the following affiliates: listed here.

How To Exercise your MHMDA or Nevada CHD Law Rights

Subject to exceptions, the MHMDA and Nevada CHD Law extends certain rights to CHD. Depending on your jurisdiction, this may include requests (1) to confirm whether Ro is collecting, sharing or selling your CHD; (2) to access your CHD; (3) to delete your CHD; and (4) to withdraw your consent to the collection or sharing of your CHD. You can seek to exercise these rights through this webform. Depending on the nature of your request, we may contact you for further information if appropriate to authenticate your identity.  Note, however, that Ro will never ask you for sensitive personal or financial information when authenticating your identity, and no Ro employee will ask you to tell them your password.

If we deny your request in whole or in part, you may appeal that decision by: webform. If you are a resident of Washington and your appeal is denied, you can contact the Washington State Attorney General at www.atg.wa.gov/file-complaint. If you are a resident of Nevada and your appeal is denied, you can contact the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/. 

Updates to this CHD Policy 

We reserve the right to change this CHD Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised CHD Policy accessible through the Services, so you should review it periodically. The date this CHD Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the CHD Policy. If we make a material change to the CHD Policy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites or Apps after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this CHD Policy.

Contact Us

If you have any questions about this CHD Policy or Ro's privacy practices, please contact us at:

Roman Health Ventures Inc. 625 6th Ave, 4th Floor New York, NY 10011 [email protected]