Effective Date: October 26, 2026
This Consumer Health Data Privacy Policy (“Policy”) applies solely to personal information defined as “Consumer Health Data” subject to the Washington My Health My Data Act (“MHMDA”), the Nevada Health Data Privacy Act (“NHDPA”), or other applicable state consumer health privacy laws. This Policy supplements the Zerene Inc. (“Zerene”) Privacy Policy and any other privacy policies applicable to our products.
What does this Policy cover?
This Policy describes what Consumer Health Data we collect, how we collect and use it, who we disclose it to and why, and the choices you may have regarding our use or disclosure of your Consumer Health Data.
When we say “Consumer Health Data” in this Policy, we mean 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 by the MHMDA and the NHDPA. Consumer Health Data does not include, among other things, data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual, or other deidentified information. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
How do we collect, use, and disclose Consumer Health Data?
To provide our products or features, we collect and process information about you, including information that may be considered Consumer Health Data. The best way to learn about the types of information we collect and how we use them is to review the Zerene Privacy Policy and other privacy policies applicable to our products.
For those covered by this Policy, the summary below provides a summary of our practices in relation to Consumer Health Data, to the extent personal information we collect about you is considered Consumer Health Data. In each case, our practices depend on how you interact with Zerene and our products, and the information that you choose to share with us (as in many instances, providing your Consumer Health Data to us is voluntary).
Categories of Consumer Health Data that we may collect
We may collect or receive the following categories of personal information which may be considered Consumer Health Data. Not all categories will be collected or received for every individual.
- Information that identifies health conditions, including sleep conditions, status, treatment, symptoms, diseases, and diagnoses
- Measurements of bruxism behavior
- Location information (for Bluetooth)
- Other health information, including information that may be used to infer or that is derived from data related to the above
Categories of sources of Consumer Health Data
- You (including from information from your activity with our products or that you provide directly to us (i.e., through the profile survey))
- Your device(s)
Purposes for which we may collect, use and disclose Consumer Health Data
We collect, use, and disclose Consumer Health Data for the purposes described in our Privacy Policy and as reasonably necessary to provide you with the products and services you have requested. This may include:
- Providing and personalizing our products and services
- Enhancing the safety and security of our products
- Personalized communications you choose to receive containing your device data and metrics (such as session emails or monthly reports)
- Communicating with you and responding to your inquiries
- Complying with applicable legal obligations
- Research and development, including analyzing and measuring trends, conducting aggregate analysis to inform future product development, and using deidentified data to improve Zerene services, develop new features, and publishing aggregate research findings that do not identify you
We may also collect, use, and disclose Consumer Health Data for other purposes with your consent or authorization or as otherwise permitted by law.
Categories of parties with whom Consumer Health Data may be disclosed
- New owners in the event of a change of ownership or control of all or part of our products or their assets changes
- Law enforcement or other third parties in connection with legal requests, to comply with applicable law
- Other third parties, with your consent or authorization
How do you exercise your rights regarding Consumer Health Data?
Depending on where you live and subject to certain exceptions, you may have certain rights related to your Consumer Health Data. This includes the right to (1) request that we confirm whether we are collecting or disclosing your Consumer Health Data (and to whom); (2) request access to your Consumer Health Data; (3) confirm whether we have disclosed or sold your Consumer Health Data; (4) request the deletion of your Consumer Health Data; and (5) request withdrawal of your consent or authorization relating to such data, including the collection and sharing of your Consumer Health Data.
Your Requests
You may request account deletion through the Zerene mobile app or submit privacy requests by emailing privacy@zerenelife.com.
To protect your information, we may need to verify your identity before fulfilling a request. We will respond without undue delay and generally within 45 days, subject to applicable law. Where permitted and reasonably necessary, we may extend this period once by up to 45 additional days, notifying you of the reason for the extension within the initial response period.
We provide responses to at least two privacy requests per 12-month period at no charge. Additional requests will also be handled without charge unless applicable law permits a reasonable fee, such as for requests that are manifestly unfounded, excessive, or repetitive.
If we decline your request, we will explain the reason and how to appeal by contacting privacy@zerenelife.com. We will respond to appeals within 45 days. If your appeal is denied, you may contact the relevant state Attorney General, including:
Additional rights relating to Consumer Health Data are described in our Consumer Health Data Privacy Policy.
Third-Party Tracking and Consumer Health Data
As described in our Privacy Policy, third-party advertising and analytics services may collect information about visitors' online activities over time and across different websites or online services.
Zerene does not intentionally disclose individual health survey responses, diagnoses, or device-derived health metrics to third-party advertising services for cross-site advertising purposes.
Material changes to this policy
We will make commercially reasonable efforts to notify you before we make material changes to this Policy. Please check this Policy periodically for updates.
Contact
If you have additional questions about this Policy, please contact us at:
Zerene Inc.
Email: privacy@zerenelife.com
