consumer health data privacy notice

This CHD Privacy Notice supplements the Privacy Policy of The College of Diabetes Network, Inc., d/b/a The Diabetes Link (“The Link,” “we,” “our,” or “us”), and applies specifically to “Consumers” as defined under applicable U.S. privacy laws regarding consumer health data (collectively, the “CHD Privacy Laws”)

This CHD Privacy Notice describes The Link’s practices regarding the collection, use, sharing and disclosure of consumer health data (“CHD”).

Generally, CHD includes personal information that is linked or reasonably linkable to a Consumer and that is collected or processed in connection with the Consumer’s past, present, or future physical or mental health status, condition or diagnosis.

Importantly, CHD does not include certain information, including protected health information subject to the Health Insurance Portability and Accountability Act and its related regulations.

We collect the following categories of CHD and share these categories of CHD with third parties, as described below in the Section of this CHD Privacy Notice called “Our Sharing of CHD”:

• Individual health conditions, treatment, diseases, or diagnosis;
• Health-related procedures;
• Use or purchase of medication;
• Bodily functions, vital signs, symptoms, or measurements of other types of CHD;
• Diagnoses or diagnostic testing, treatment, or medication;
• Data that identifies a Consumer seeking health care services; or
• Other information that may be used to infer or derive data related to the above or other health information.

We may collect this information from you directly and our service providers.

We—and our service providers—collect, process and use the CHD described in this CHD Privacy Notice for the following purposes:

• Providing our services, events, local meetups and resources as may be reasonably expected by an average Consumer who requests those services and/or resources or attends those events and/or local meetups;
• Processing or fulfilling donations, verifying donation information, processing payments;
• Taking measures to ensure the security and integrity of our website and services to the extent the use of the Consumer’s CHD is reasonably necessary and proportionate for these purposes;
• Undertaking activities to verify or maintain the quality or safety of our services, or to improve, upgrade, or enhance our website or services;
• Performing accounting, audit, and other internal functions, such as internal investigations;
• Complying with law, legal process, and internal policies;
• Maintaining business records;
• Investigating, establishing, exercising, preparing for, and defending against legal claims; and
• Otherwise accomplishing our business purposes and objectives.

Service Providers. We may disclose CHD to our service providers in order to enable them to provide us with services, such as web hosting, payment processing, customer service, infrastructure provisioning, IT services, email and direct mail delivery services, auditing, legal services, and other similar services that are essential to our provision of our website, services, resources, events and/or local meetups.

Third Parties. We may disclose your CHD to the following categories of third parties:

• Business Transfers or Assignments. We may disclose your CHD to other entities as reasonably necessary to facilitate a reorganization, merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
• Legal and Regulatory. We may disclose your CHD to government authorities, law enforcement, courts, or similarly situated third parties for our business operational purposes, to investigate, establish, exercise, prepare for and/or defend against legal claims, and otherwise as permitted or required by law.
• Other Third Parties at Your Direction. We may disclose your CHD to any third party with your consent or at your direction.

Please note that third parties will not collect CHD over time and across different Internet websites or online services when a Consumer uses The Link’s website.

We do not sell CHD.

Consumers have certain rights under the CHD Privacy Laws with respect to the collection, use and sharing of their CHD. These rights may include:

• The right to confirm whether we collect, share or sell your CHD;
• The right to access such CHD, including a list of the third parties and affiliates to whom the information may have been sold or shared and their relevant contact information;
• The right to obtain a copy of your CHD we and our service providers process, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means;
• The right to correct inaccuracies in your CHD;
• The right to withdraw consent from our collection and sharing of CHD; and
• The right to delete your CHD.

Consumers may exercise any of these by emailing privacy@thediabeteslink.org.

We reserve the right to amend this CHD Privacy Notice at our discretion and at any time. When we make material changes to this CHD Privacy Notice, we will notify you by posting an updated CHD Privacy Notice on our website, including the effective date of such updates. We may also provide notice by email or through a pop-up banner on our website, where appropriate.

If you have any questions or concerns about this CHD Privacy Notice, please contact us at privacy@thediabeteslink.org or The Diabetes Link, 50 Milk Street, 16th Floor, Boston, MA 02109, Attn: Privacy Policy.