Effective: January 2025
This Consumer Health Data Privacy Policy (the “Consumer Health Policy”) supplements the Dompé Privacy Policy and explains how Dompe (“Dompe,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes Consumer Health Data (as defined below) of residents of the state of Washington or Nevada, or individuals whose Consumer Health Data is collected in those states through the www.dompe.com website (the “Site”). In addition, this Consumer Health Policy covers the related content, products, services, or other functionality offered on or through the Site (all collectively, the “Service”).
This Consumer Health Policy does not address privacy practices relating to Dompe job applicants, employees, and other personnel. Please note that this Consumer Health Policy is not a contract and does not create any legal rights or obligations not otherwise provided by law.
As required by law, Dompe will obtain additional consent for collecting, using, sharing, or selling your Consumer Health Data. We may change or add to this Consumer Health Policy, so we encourage you to review it periodically.
Our Collection and Use of Consumer Health Data
The term “Consumer Health Data” as used in this Consumer Health Privacy Policy means any personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Washington My Health My Data Act or the Nevada Consumer Health Data Privacy Law (the “Consumer Health Privacy Laws”). The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, is information that you decide to share with us. This includes information collected through clinical trials, your communications with us, or from your other interactions with our Service. Consumer Health Data does not include information that is considered deidentified under the Consumer Health Privacy Laws.
Examples of Consumer Health Data that we may collect include:
- Information related to your medications, medical history, medical insurance details, physical and mental health conditions, diagnoses, treatments, genetic information, and family medical history.
- Information you provide when you elect to be enrolled in the Dompé U.S.’ patient support program Dompé CONNECT to Care (“DC2C”), such as, personal, demographic, contact and health and treatment information with Dompé U.S. and or certain third parties working with or for Dompé U.S. to provide you Services related to your prescription for a Dompé U.S. product.
- Information you share about your health-related conditions, symptoms, experiences, diagnoses, testing, or treatments.
- Any health-related information that you share with Dompe.
- Other information that may be used to infer or derive data related to the above or other healthrelated information.
We may process and/or use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes:
- To manage and provide the Service (including clinical trials and DC2C).
- To manage, provide, maintain, and improve the business.
- To respond to your questions, concerns, and other requests for assistance.
- To customize your browsing experience on the Service.
- For market research and providing insights into consumer health behaviors/conditions.
- To create anonymous, aggregated, or de-identified data
We may also combine your Consumer Health Data with other personal information we collect directly from you or receive from other sources.
1. Sources of Consumer Health Data
The Consumer Health Data we collect depends on the context of your interactions with our Service and, in most cases, is information that you decide to share with us. We and our service partners may collect this type of information over time and across third-party websites and mobile applications. For more information, please see the “Information We Collect” section of our Privacy Policy.
2. Our Disclosure of Consumer Health Data
We may share the categories of Consumer Health Data set forth above as follows:
- Authorized Third Parties: We may share Consumer Health Data with health plans, health care providers, healthcare clearinghouses, and their business associates as outlined in the “Information We Collect” section of our Privacy Policy.
- Service Providers: We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the operation of our Site and Service and to support our communications, and advocacy programs.
- Business Transactions: We may take part in or be involved with a business transaction, such as a merger. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction.
- Legal Obligations and Rights: We may disclose Consumer Health Data to third parties: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.
- With Your Consent: We may disclose Consumer Health Data about you to other service providers or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction we may post their testimonial on our Site or Service-related publications.
3. Your Privacy Rights
The Laws provide the following rights with respect to Consumer Health Data we collect about you:
- Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
- Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.
- Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.
4. How to Exercise Your Privacy Rights
To exercise any of the privacy rights set forth above or to review or request changes to data, please submit a request to privacy@dompe.com.
Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including, but not limited to, your email address and phone number.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.
5. Appealing Privacy Rights Decisions
If your request to exercise a right under the Laws is denied, you may appeal that decision by contacting us at privacy@dompe.com or call us at 1 (800) 868-2185. If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable State Attorney General:
- Washington: www.atg.wa.gov/file-complaint
- Nevada: ag.nv.gov/Complaints/File_Complaint/
6. Changes to this Consumer Health Data Privacy Policy
We may update this Consumer Health Policy from time to time. When we make changes to this Consumer Health Policy, we will notify you by changing the date at the beginning of this Consumer Health Policy. If we make material changes to this Consumer Health Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.
