Consumer Health Data Privacy Policy

Total Life ("Total Life" "we," or "us") owns and operates a website (the "Website") located at www.totallife.com, including all affiliated sites, subdomains, and associated digital properties (collectively, the "Platform"). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content ("Content"), any products or services provided through the Platform or otherwise by Total Life, and any affiliated website, software or application owned or operated by Total Life (collectively, including the Platform and the Content, the "Service") are subject to our Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in our Privacy Policy or this Consumer Health Data Privacy Policy have the same meaning as set forth in the Terms of Service ("Terms of Service").

This Consumer Health Data Privacy Policy ("Consumer Health Data Privacy Policy") our general Privacy Policy and applies to personal data defined as “consumer health data” (“CHD”) by the Washington state My Health My Data Act (“MHMDA”), Nevada’s Consumer Health Data Privacy Law (“Nevada CHD Law”), and Connecticut’s Data Privacy Act (“CTDPA”). For example, this Consumer Health Data Privacy Policy does not apply to protected health information subject to the Health Insurance Portability and Accountability Act of 1996 if applicable to data collected by Total Life. Please refer to the Notice of Privacy Practices which governs such information. In the event of a conflict between our Privacy Policy and the Consumer Health Data Privacy Policy, the Consumer Health Data Privacy Policy applies to the extent that it is consistent with applicable state law.

Collection of Consumer Health Data

The Consumer Health Data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect Consumer Health Data about you from different sources and in various ways when you use our services, including Consumer Health Data you provide directly, Consumer Health Data collected automatically, Consumer Health Data we obtain from third-party data sources, and Consumer Health Data we infer or generate from other data.

Consumer Health Data you provide. We collect Consumer Health Data you may provide to us. For example:

• Name and contact information, including your name, email address, phone number, and billing or physical addresses.
• Demographic information, such as your gender, race or ethnicity, date of birth, and ZIP code.
• Payment information, including your credit card details, financial account numbers, and other payment-related data.
• Account profile information, such as your username, account number, password, security codes, redemption codes, biographical details, social media profiles, interests, preferences, and any other details added to your profile.
• Marketing information, including your communication preferences and how you interact with our marketing content.
• Content, such as photographs, videos, documents, and other files you upload to the Service. This includes email messages and the content of other communications you send to us.
• Government-issued identifiers, such as driver’s license number, passport number, or other government issued ID number. We may collect images of such identification cards.
• General Health Data, such as information concerning your physical and/or mental health status.
• Sexual health information, such as information about your sexual orientation, preferences, and gender identity.

Consumer Health Data we collect automatically. When you use our services, we collect some information through certain website tracking technologies that may be considered Consumer Health Data. For example:

• Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the “Cookies, Web Beacons and Other Similar Online Tracking Technology” section of our Privacy Policy, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
• Location data. We may collect general location data when you use our online services.
• Usage data. We automatically log your activity on our websites and any applicable connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website. In some instances, such usage data may be related to browsing activity on health-specific sites.

Consumer Health Data we create, infer, or generate. We may use the information we collect to learn or make educated guesses about your health-related preferences or traits, sometimes using automated tools to do so.

Consumer Health Data we obtain from third-party sources. We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:

• Corporate affiliates. We may obtain your Consumer Health Data from our corporate affiliates.
• Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services.
• Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
• Service providers. Third parties that collect or provide data in connection with work they do on our behalf.
• Publicly available sources. Public sources of Consumer Health Data such as open government databases.

Use of Consumer Health Data

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

Purpose of Use	Categories of Consumer Health Data
Product and service delivery. To provide and deliver our Service and operate our business, including analyzing Service use, troubleshooting, facilitating your movement through the Service, confirming your location, billing, processing your payments, accounting, administering your account, securing our systems, detecting fraudulent or illegal activity, providing customer support, communicating with you about the Service, personalizing the Service, verifying your identity and complying with our legal obligations and enforcing our rights.	Contact information, demographic data, payment information, content and files, identifiers and device information, location data, usage data, inferences, government ID, account access information, general health data, information about sex assigned at birth and orientation.
Product improvement, development, and research. To develop, test, or improve the Service and content, features and/or products or services offered via the Service. Additionally, to Identify or create new products or services. Lastly, to analyze traffic and user behavior or activity to and through Service.	Contact information, demographic data, payment information, content and files, identifiers and device information, usage data, inferences, government ID, account access information, location data, genetic data, general health data, information about sex assigned at birth and orientation.
Aggregation, de-identification and/or anonymization. We may create aggregated, de-identified and/or anonymized data from your Consumer Health Data. We make Consumer Health Data into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to re-identify such data other than if required by applicable law. We may use and disclose this aggregated, de-identified and/or anonymized data with third parties.	Contact information, demographic data, payment information, content and files, identifiers and device information, location data, usage data, inferences, government ID, account access information, general health data, information about sex assigned at birth and orientation.
Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners.	Contact information, demographic data, payment information, content and files, identifiers and device information, location data, usage data, sensor data, inferences, general health data, information about sex assigned at birth and orientation.

Sharing Consumer Health Data

We may “share” (as applicable state law defines that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide the services you have requested or authorized, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data to:

• Affiliates. We enable access to Consumer Health Data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business. We may also share your consumer health data with our affiliates as needed to provide the services.
• Legal and law enforcement. We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others.

Your Consumer Health Data Rights

You may have certain rights to your Consumer Health Data under applicable state law. These rights may vary depending on your state of residence. Any of the rights discussed below may be subject to certain limitations.

If you wish to exercise these rights, please email us at Privacy@totallife.com. These rights, depending on your jurisdiction, may be:

• Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.
• Access and confirm. You have the right to ask if we’ve collected, shared, or sold your Consumer Health Data. You can also request a copy of that data. In addition, you can ask for a list of third parties and affiliates we’ve shared or sold your Consumer Health Data with, along with related details.
• Correction. You have the right to ask us to correct inaccuracies in your Consumer Health Data.
• Deletion. You have the right to ask us to delete your Consumer Health Data.
• Appeal. You have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.

To exercise your rights above and make a Consumer Health Data rights request, please email us at: Privacy@totallife.com. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.

If we deny your request in whole or in part, you may appeal that decision by emailing us at: Privacy@totallife.com. 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/. If you are a resident of Connecticut and your appeal is denied, you can contact the Connecticut Attorney General at https://www.dir.ct.gov/ag/complaint/e-complaint.aspx.

We need to collect certain Consumer Health Data in order to provide the Service to you. If you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide the Service or certain features of the Service to you.

Changes to this Consumer Health Data Privacy Policy

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Consumer Health Data Privacy indicates your acknowledging that the modified Consumer Health Data Privacy Policy applies to your interactions with the Service.

Contacting Us

If you have any questions about this Privacy Policy, please contact us by email at Privacy@totallife.com.