1. Consumer health data we collect
Health conditions, diagnoses, medications, dosages, and administration schedules; daily health and wellbeing logs such as mood, sleep, appetite, pain, energy, and mobility; self-assessments; reported health events such as falls, hospitalizations, memory issues, or medication errors; Ask a Care Navigator conversations that may contain health information; insurance information, including consumer health data reflected in those records; and any health-related documents you choose to upload.
This may include consumer health data about a person who is not a registered user, such as a care recipient, subject to the consent requirements in section 3.
2. Purpose for collecting and processing it
We collect and process consumer health data to provide and personalize the Services — including Ask a Care Navigator responses, care log tracking, and the household sharing you enable; to provide customer support; to maintain the security of the Services; to comply with applicable law; and to create aggregated or de-identified data as described in the Privacy Notice.
We do not process consumer health data to advertise or market products or services to you based on that data without your separate consent where applicable law requires it.
3. Consent to collect and process
We obtain your consent, or rely on another permissible basis under applicable law, before collecting or processing your consumer health data for a purpose not described in this policy.
If you provide consumer health data about another person who is not a registered user, such as a care recipient, OMMPO requires a separate consent or authorization step directed to that person's consumer health data. That may include an attestation and documentation of your legal authority to act for them, or direct outreach to that person where feasible. Your representation that you have permission to enter another person's information, standing alone, does not satisfy this requirement.
We will obtain your valid authorization, as defined by applicable law, before selling your consumer health data, and your separate affirmative consent before sharing it with a third party for a purpose other than providing the Services — in each case to the extent applicable law requires.
4. Sharing of consumer health data
OMMPO does not sell consumer health data and would not do so without your valid authorization as required by MHMDA and similar laws. OMMPO does not share consumer health data with any third party for that third party's own purposes.
We disclose consumer health data only to the service providers identified in the Privacy Notice — including Anthropic, Resend, and Stripe — which process it on our behalf under a written contract limiting their use of that data to providing services to OMMPO, or as otherwise required or permitted by law.
5. Your rights regarding consumer health data
Subject to certain exceptions under applicable law, you have the right to confirm whether OMMPO processes your consumer health data; access it; withdraw your consent to its collection or processing; and request deletion, which we will honour and instruct our processors and any affiliates who received the data to also delete.
If you are a non-user third party about whom consumer health data was entered, such as a care recipient, you have these same rights, as described in the Privacy Notice. To exercise a right, email info@ommpo.com. We may ask for information reasonably necessary to verify your identity and, if applicable, your relationship to the data at issue. If we deny your request we will explain why, and you may appeal using the appeal process in the Privacy Notice.
6. Security and retention
We protect consumer health data using the administrative, physical, and technical safeguards described in the Security section of the Privacy Notice, and retain it as described in that Notice's Retention section.
7. Geofencing
OMMPO does not use geofencing to establish a virtual boundary around a mental health facility, reproductive or sexual health facility, or other healthcare facility in order to identify, track, collect data from, or send a notification, message, or advertisement to a consumer regarding their consumer health data, as prohibited by MHMDA.
8. Changes to this policy, and contact
We may update this policy as our practices or legal obligations change. If we make a material change we will notify affected consumers and, where applicable law requires, obtain renewed consent before applying the change to previously collected consumer health data.
OMMPO LLC, New York City, New York — info@ommpo.com. You can also contact us through the website.
