This Knightley Consumer Health Data Policy ("WA Policy") applies to "Consumer Health Data" under the Washington State My Health My Data Act ("MHMDA") relating to consumers residing in the State of Washington and consumers whose Consumer Health Data is collected in the State of Washington ("you"). This WA Policy explains how Wheelhouse Growth Advisors LLC ("Knightley," "we," or "us") collects, uses, and shares this information, as well as your rights and choices regarding such information. Our WA Policy applies to our Website, mobile application, and any channel that you may interact with us as part of the Services, including via email, chat, or phone.
Capitalized terms not defined in this WA Policy are defined in the Terms.
1. Consumer Health Data We Collect and Its Sources
Consumer Health Data You Provide
We collect Consumer Health Data you provide directly via the Services.
Consumer Health Data we may collect, if you elect to provide it depending on your role in our Services, includes reproductive or sexual health information such as menstrual cycle data (start date of last cycle and cycle length) and any identifiers provided together or in connection with such information, such as name and email address.
You may choose to voluntarily submit other Consumer Health Data to us through the Services that we do not request, and, in such instances, you dictate the extent of such information you provide and are solely responsible for such information.
Provision of menstrual cycle information is optional and not required to use our Services. Do not provide any Consumer Health Data regarding you or any third party, including your partner, that is not identified as required or optional to use the Service.
You are solely responsible for the Consumer Health Data you provide or make available to us, and in particular, any information regarding a third party, such as your partner. By submitting any information about your partner, you agree that you have provided any notices and obtained any consents and authorizations that may be legally required for us to collect and use such Consumer Health Data as described in this WA Policy. We may request consent to collect and process certain data where required by law or at our sole election.
You may not provide information that is obscene, defamatory, infringing, malicious, or that violates any law.
Information from Other Sources
We may obtain information about you from other sources, including your partner, who may have provided us with information about you.
2. How We Use Information
We may collect and use Consumer Health Data for various business and operational purposes, including to:
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Manage and provide our Services, including your registration, establish and maintain your account (as applicable), and process transactions, secure and optimize our Services, and communicate with you about Service-related updates and notifications. Your ratings of suggestions the Service provides are used to improve the suggestions provided to you. As set forth in the Terms, the Services utilize artificial intelligence technology.
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Perform Services requested by you, such as to make suggestions, respond to your comments, questions, and requests, and provide customer service.
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Monitor and analyze trends, usage, and activities regarding our Services.
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Prevent or take action regarding illegal activities, including suspected or actual fraud; protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); enforce our Terms; and conduct, complete, or respond to audits or audit results.
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Comply with any applicable law, regulation, legal process, or governmental request.
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Fulfill any other business or commercial purposes disclosed to you at your direction or with your consent.
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Menstrual cycle data specifically is:
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Used solely to pick pre-drafted suggestions we provide and ensure we provide the best suggestions over time.
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Not sold or shared with advertisers, ad networks, or marketing platforms.
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Not sent to third-party analytics or tracking services.
3. Sharing of Information
We may disclose your Consumer Health Data with our processors, vendors, and service providers as necessary to provide you the Services. We may "share" (as defined by the MHMDA) any of your Consumer Health Data as follows:
Government or public authorities, parties to litigation and others: We may share Consumer Health Data with a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; (b) to enforce our agreements, policies and terms of service; (c) to protect the security or integrity of our Services, (d) to protect the property, rights and safety of Knightley, our users or the public from harm or illegal activities; (e) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing harm to any person; or (f) to investigate and defend ourselves against any third-party claims or allegations.
4. Your Choices
Access and Delete Your Information
MHMDA provides certain rights to you with respect to your Consumer Health Data, subject to certain exceptions. You have the right to access and request deletion of your Consumer Health Data we may have collected or disclosed.
Withdraw Consents You Provided
If you provided consent for the processing of Consumer Health Data, you may withdraw this consent at any time.
Submitting, Verifying, and Responding To Requests
To submit a request, you or your authorized agent may contact us as set forth below. Please indicate in your correspondence that you are making a request pursuant to your "Washington Consumer Health Data Privacy Rights" and provide us with the following information: (1) name; (2) email address; (3)...
Before we fulfill a request, we will verify your identity and ability to exercise these rights. Exclusions and exceptions may apply to our obligations to fulfill a request. So that we can verify your identity, if you have an account with us, we may require you to first sign into your account or use your account to fulfill your request. If you do not have an account with us, you will be asked to provide certain information. If we are unable to verify your identity, we may request additional information reasonably necessary to authenticate your identity and the request.
We will not discriminate against you for exercising any of your rights.
You have the right to appeal our refusal to act on your request. If your appeal is denied, you may submit a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
5. Changes to the WA Policy
We encourage you to periodically review this WA Policy. We may occasionally update this WA Policy to reflect changes in our operations or applicable laws, and we reserve the right to do so at any time. When a revision is made, we will revise the date of last update on this page and any changes will be effective immediately upon posting of the revised WA Policy. We may provide you with additional notice of the revised WA Policy (by email or via other channels), as required by law. Your continued use of our Services indicates your consent to the WA Policy then posted.
6. Contact Us
If you have any questions about this WA Policy or you wish to submit a request in accordance with the above, you may contact us by email at hello@getknightley.com or by postal mail at Wheelhouse Growth Advisors LLC, 870 South Colorado Blvd. STE D #1079, Glendale CO 80246.