Effective Date: July 1, 2024
At Brightline, Inc. (“Brightline” and “hellobrightline.com”), we are committed to protecting the privacy and security of your personal health data. This Privacy Policy supplements the Brightline Privacy Policy ( https://www.hellobrightline.com/privacy-policy/) and applies to personal information that falls within the definition of “consumer health data” under applicable state privacy laws including, but not limited to, the below privacy laws. We encourage you to review the Brightline Privacy Policy to learn more about our privacy practices and our commitments to you. Capitalized terms used below have the same definitions as in the Brightline Privacy Policy unless otherwise noted.
California Consumer Privacy Act
Colorado Privacy Act
Connecticut’s Data Privacy Act
Montana Consumer Data Privacy Act
Nevada Consumer Health Data Privacy Law
Oregon Consumer Privacy Act
Texas Data Privacy Act
Utah Consumer Privacy Act
Virginia Consumer Data Privacy Act
Washington’s My Health Data Act
This privacy policy does not apply to third-party websites or products. We strongly suggest you review their privacy policies to understand how your personal information is used and stored by those third parties.
We collect the following categories of consumer Health Data from consumers that includes but is not limited to:
Personal information (name, contact details)
Health information (medical history, symptoms, diagnosis, treatment plans)
Social, psychological, behavioral, and medical interventions
Device and usage information (IP address, device type, browser information)
Precise location information that could reasonably indicate a consumer's attempt to acquire or receive health services or supplies
Health-related data that have been derived or inferred from the above.
We collect personal health data from you when you interact with our platform, including when you sign up for our services, participate in assessments, and communicate with our healthcare professionals. We may collect consumer health data in the following ways:
Directly from you such as when you fill out an assessment in our mobile app;
Your mobile device and web browser when accessing our Websites and Products such as when you view content that could indicate your health condition;
Your parent or guardian if you are under 18 and required your parent or guardian’s permission;
Your other third-party apps or other third-party services with which you have integrated or linked your Brightline account; and
Your other health or wellness providers.
We use the collected information to provide and improve our services, personalize your experience, and communicate with you. Specifically, we may use your data for:
Providing healthcare services and support
Tailoring our services to meet your needs
Communicate with you regarding our platform including updates, new features, promotions, or changes
Processing your payments for your subscription or other purchases
To fulfill our obligations under any agreements that we may have with you
Conducting research and analysis to enhance our offerings
Complying with legal and regulatory requirements
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Data
To create and maintain a trusted, secure, and reliable online environment
We do not sell, trade, or rent your personal health data to third parties for marketing purposes. However, we may share your information with:
Healthcare providers and professionals involved in your care.
Service providers, including our affiliated professional corporations, who assist us in delivering our services.
Legal and regulatory authorities as required by law or to protect our rights.
Other users. If you engage with other platform users or other individuals, we may share your consumer health data as directed by you such as when you use our community features to post on a comment board.
Payment processors. When you purchase something from us, we may share your consumer health data as necessary for that transaction such as your credit card provider.
Business partners. In limited cases, we may share consumer health data with other businesses with which we have a joint promotional relationship, bundled subscription offer, or other service offering that is jointly operated.
Other third parties. We may share your consumer health data with other third parties with your consent or, if necessary, in accordance with applicable law, we may share your consumer health data in certain circumstances to protect our rights, our customers, or your safety.
We implement appropriate technical and organizational measures to protect your personal health data from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, and regular security assessments.
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material updates and seek your consent if required by law.
By using hellobrightline.com, you consent to the collection and use of your personal health data as described in this Privacy Policy.
As outlined in the Brightline Privacy Policy, you may make requests about your personal information. Applicable privacy laws provide you certain specific rights with respect to your consumer health data law subject to exceptions.
Member’s Privacy Right: Right to access
Description: the data we hold that is about you, delivered to you in a readable format.
State: California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia, Washington
Member’s Privacy Right: Right to know
Description: what consumer health data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
State: California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia, Washington
Member’s Privacy Right: Right to have us, as well as our affiliates, service providers, and contractors, delete
Description: the consumer health data we have about you (with some exceptions).
State: California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia, Washington
Member’s Privacy Right: The right to opt-out
Description: related to your consumer health data where we rely upon consent to collect, use, or share your consumer health data.
(i.e. targeted advertising, the sale of your consumer health data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer).
State: California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, Virginia, Washington
Member’s Privacy Right: The right to have us correct inaccurate
Description: consumer health data
State: California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Virginia, Washington
Member’s Privacy Right: The right not to receive discriminatory treatment
Description: You have the right not to receive discriminatory or retaliatory treatment for making a request.
State: California, Connecticut, Montana, Oregon, Texas, Utah, Virginia, Washington
You may exercise your rights by contacting [email protected] with your request. As further stated in the Brightline Privacy Policy, your request may be denied where an exception applies, including but not limited to, where we are legally required to maintain your consumer health data, for treatment, payment, or healthcare operations purposes under HIPAA, or if we are unable to authenticate the request using commercially reasonable efforts.
We will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.
California. If you are a California resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may submit a complaint with the California Attorney general at https://cppa.ca.gov/webapplications/complaint.
Colorado. If you are a Colorado resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. If the appeal is denied, you may submit a complaint with the Colorado Attorney general at https://coag.gov/file-complaint/.
Connecticut. If you are a Connecticut resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may submit a complaint with the Connecticut Attorney general at https://www.dir.ct.gov/ag/complaint/.
Montana. If you are a Montana resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Montana Attorney General at https://dojmt.gov/consumer/.
Nevada. If you are a Nevada resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
Oregon. If you are a Oregon resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Oregon Attorney General at https://justice.oregon.gov/consumercomplaints/.
Texas. If you are a Texas resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If the appeal is denied, you may submit a complaint with the Texas Attorney general at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.
Virginia. If you are a Virginia resident or located in Virginia and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Virginia’s State Attorney General at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint
Washington. If you are a Washington resident or located in Washington and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision. If your appeal is not successful, you may submit a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.