1. Introduction and Scope
GlucoWorks LLC, a Wyoming limited liability company, doing business as CGMInsight™ (“GlucoWorks,” “Company,” “we,” “our,” or “us”), provides this Consumer Health Data Privacy Policy (this “Policy”) to comply with the Washington My Health My Data Act (MHMDA, RCW 19.373), the Nevada Consumer Health Data Privacy Act (SB 370), and other applicable state consumer health data privacy laws.
This Policy describes how we collect, use, share, and protect “Consumer Health Data” as defined under these laws. This Policy supplements—and should be read in conjunction with—our general Privacy Policy.
This Policy applies to Consumer Health Data that you provide directly to us or that we collect from you outside the scope of HIPAA—for example, through the GlucoWorks corporate website (gluco-works.com), contact forms, marketing interactions, and related communications.
2. What Is Consumer Health Data?
Under applicable state consumer health data privacy laws, “Consumer Health Data” generally means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. Depending on the jurisdiction, this may include:
- Health Conditions, Treatments, Diseases, or Diagnoses: Information about specific health conditions, including diabetes, that you may disclose to us through contact forms, demo requests, or other communications outside the HIPAA-regulated platform.
- Product Interests Indicating Health Status: Information about your interest in our health-related products and services (e.g., inquiries about CGM documentation software, insulin management tools, or RPM billing workflows) that could indicate a health condition or interest.
- Bodily Functions and Vital Signs: Any glucose data, A1c values, or other health metrics you may voluntarily share with us outside the CGMInsight™ platform (e.g., in a support inquiry or feedback communication).
- Health-Related Searches and Browsing: Information about your interaction with health-related content on our Website that could identify a health status or interest.
3. Categories of Consumer Health Data We May Collect
GlucoWorks may collect Consumer Health Data in the following limited categories through the corporate Website and related business communications:
| Category | Examples | Source |
|---|---|---|
| Product Interests | Interest in diabetes management software, CGM documentation tools, or insulin dosing platforms | Contact forms, demo requests, email inquiries |
| Professional Health Context | Medical specialty (endocrinology), practice focus areas, patient population descriptions shared in business context | Contact forms, sales conversations, partnership inquiries |
| Voluntarily Disclosed Health Information | Health conditions or clinical scenarios described in support inquiries or feedback outside the platform | Email correspondence, contact form free-text fields |
4. How We Collect Consumer Health Data
We may collect Consumer Health Data from the following sources:
- Directly from you: When you submit information through the Website’s contact form, request a demo, send us an email, or otherwise communicate with us.
- Automatically from the Website: Through standard web technologies such as cookies and server logs when you visit health-related pages on the Website. However, we do not use analytics or tracking specifically designed to infer health status from browsing behavior.
GlucoWorks only collects, uses, and discloses Consumer Health Data as necessary to respond to your inquiries, provide you with information about our products and services, and for the other purposes described in Section 5.
5. How We Use Consumer Health Data
We use Consumer Health Data for the following purposes:
- Responding to Your Requests: To respond to contact form submissions, demo requests, and other inquiries about our products and services.
- Providing Information: To send you information about GlucoWorks products and services that may be relevant to your interests, with your consent where required.
- Business Operations: To manage our customer relationship management (CRM) system and to understand the needs of potential customers.
- Security and Fraud Prevention: To protect the security of the Website and to detect and prevent fraudulent or malicious activity.
- Legal Compliance: To comply with applicable laws, regulations, and legal processes.
We do not use Consumer Health Data for advertising, marketing to third parties, or any purpose unrelated to providing you with information about GlucoWorks products and services.
6. How We Share Consumer Health Data
We do not sell your Consumer Health Data. We do not share Consumer Health Data for advertising purposes.
We may share Consumer Health Data with third parties only in the following circumstances:
- Service Providers: We may share Consumer Health Data with service providers who help us operate our business (e.g., CRM providers, email service providers, website hosting), under contractual obligations to protect the data and use it only for the purposes for which it was disclosed.
- Legal Requirements: We may disclose Consumer Health Data if required by law, legal process, regulation, or governmental request, including to respond to a subpoena or court order, or when we believe disclosure is necessary to protect the rights, property, or safety of GlucoWorks, our users, or the public.
- Business Transfers: In connection with a merger, acquisition, reorganization, corporate conversion, or sale of assets, Consumer Health Data may be transferred as part of that transaction.
- With Your Consent: We may share Consumer Health Data when you have given us explicit consent to do so.
We may use and disclose aggregated, de-identified information that does not identify any individual for any business purpose, including analytics, research, and service improvement.
7. Your Rights
Depending on your state of residence, you may have the following rights with respect to your Consumer Health Data:
7.1 Washington Residents (My Health My Data Act)
If you are a Washington state resident, you have the right to:
- Know and Access: Confirm whether we are collecting, sharing, or selling your Consumer Health Data and obtain a list of all third parties and affiliates with whom we have shared your Consumer Health Data.
- Withdraw Consent: Withdraw your consent for the collection and sharing of Consumer Health Data at any time.
- Deletion: Request deletion of your Consumer Health Data.
7.2 Nevada Residents (SB 370)
If you are a Nevada resident, you have the right to:
- Access your Consumer Health Data that we have collected;
- Request deletion of your Consumer Health Data;
- Opt out of any sale of Consumer Health Data (we do not sell Consumer Health Data).
7.3 Other States
Residents of other states that have enacted or will enact consumer health data privacy laws may have additional rights. We will honor valid requests under applicable law. Please contact us to inquire about rights available in your jurisdiction.
7.4 How to Exercise Your Rights
To exercise any of the rights described above, please contact us at:
- Email: privacy@gluco-works.com
- Subject Line: “Consumer Health Data Request — [Your State]”
We will respond to your request within the timeframe required by applicable law (generally within thirty (30) days). We may need to verify your identity before processing your request. We will not discriminate against you for exercising your privacy rights.
8. Data Security
We implement commercially reasonable administrative, technical, and physical safeguards to protect Consumer Health Data from unauthorized access, use, disclosure, or destruction. These include encryption in transit (TLS/HTTPS), access controls, and secure business communication tools.
9. Data Retention
We retain Consumer Health Data only for as long as necessary to fulfill the purposes described in this Policy. When Consumer Health Data is no longer needed, we will securely delete or de-identify it. Specific retention periods are described in our general Privacy Policy.
10. Geofencing
In compliance with the Washington MHMDA, GlucoWorks does not use geofencing technology around healthcare facilities, medical offices, hospitals, or pharmacies to collect Consumer Health Data or to identify or track consumers seeking healthcare services.
11. Children
The Website is intended for healthcare professionals and business stakeholders, and is not directed to individuals under the age of 18. We do not knowingly collect Consumer Health Data from children. If you believe we have inadvertently collected Consumer Health Data from a child, please contact us at privacy@gluco-works.com and we will promptly delete such data.
12. Changes to This Policy
We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we update or change this Policy, the changes will be posted on this page with an updated “Last Updated” date. For material changes, we may provide additional notice at our discretion. Your continued use of the Website following the effective date of any change constitutes acceptance of the updated Policy.
13. Contact Information
If you have any questions or concerns about this Consumer Health Data Privacy Policy, please contact:
GlucoWorks LLC
Privacy Inquiries: privacy@gluco-works.com
Legal Inquiries: legal@gluco-works.com
General Inquiries: info@gluco-works.com