Washington Consumer Health Data Notice

Effective Date:  June 20, 2024

This Consumer Health Data Privacy Notice (the “Notice”) supplements our Privacy Policy https://www.getquip.com/privacy and explains our collection, use, and disclosure of personal information that is defined as “Consumer Health Data” under applicable laws including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. state health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. State Health Privacy Laws”).

“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as biometric data, information about use of non-prescription medication or use of health-related products, for example. Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship.

If we make any material updates to this Notice, we will notify you as required by U.S. State Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Notice. We reserve the right to amend this Notice at our discretion and at any time. 

Terms capitalized and not otherwise defined in this Notice have the meanings referred to in our Privacy Policy.

Consumer Health Data We Collect

We may collect Consumer Health Data when you browse our Sites or download our App or engage in transactions through our Services.  Examples of Consumer Health Data we may process include:

• Browsing Data.  When you browse our Sites, we collect information related to your browsing activities, such as the search parameters you use and the products you engage with, in order to fulfill your request or order.
• Transaction Information.  When you make a purchase or return any quip products, we collect information about these transactions, including information about the products you purchase.
• Application Information.  When you use our App, we collect the information you provide regarding your oral care routine.  
• Brushing Routine Information. When you use our App we collect information about how you are using quip products for efficacy (i.e. frequency of use, length of use, and trends of usage)

Our Use of Consumer Health Data

We use the Consumer Health Data we collect to provide you with the Services you request, as described in this Notice or as otherwise disclosed to you.  For example, we use Consumer Health Data for the following purposes:

• Product and Service Delivery.  To provide our products and Services, including securing, troubleshooting, improving, and personalizing products and Services, and processing, fulfilling, shipping, and delivering your orders.
• Business Operations.  To operate our business, such as: creating, maintaining, and renewing your subscriptions, securing our network and systems, detecting fraudulent, illegal, or unauthorized activity, and monitoring trends, usage, and activities in connection with our Services.
• Legal, Security, and Safety.  For legal, security, and safety reasons, such as to protect our rights and the rights of our customers, protect the security of our systems and network, enforce our policies, communicate product recalls or safety notices, or address legal and regulatory compliance obligations.
• Ads Administration.  To serve you with relevant ads about our Services and to measure and track the effectiveness of advertising campaigns and carrying out other administrative activities with respect to ad campaigns.
• Guiding Better Brushing Habits. To provide  personalized information to optimize your oral care routines according to dentist recommendations. This includes recommendations such as frequency of use, length of use, and proper product usage to maximize results.

Our Disclosures of Consumer Health Data

We do not sell your Consumer Health Data.  We also do not share your Consumer Health Data with any entities other than a processor or service provider as described below.

Our disclosure of Consumer Health Data is limited to the following situations:

• Service Providers.  We may disclose Consumer Health Data to our data processors, service providers, and contractors who assist us in providing Services to you.  These parties may only use the data as permitted by our contracts with them.
• Other Circumstances.  We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious, or deceptive activities, (v) as needed to preserve the integrity of our systems, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or federal law.

Your Privacy Rights 

You have specific rights with respect to your Consumer Health Data:

• You have the right to know if we are collecting, using, or disclosing your Consumer Health Data, to access that Consumer Health Data, including receiving a list of the entities with whom we have shared or sold your information, however, quip does not currently sell your Consumer Health Data and only share Consumer Health Data with processors.
• You have the right to request that we delete your Consumer Health Data.
• If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent.
• We will not discriminate against you for exercising any of your rights.  However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the Services.

To exercise these rights, please email privacy@getquip.com.  We will authenticate your requests and process it as required by law.  Please allow up to 45 days for a response.  If we deny your request, you may appeal that denial by emailing privacy@getquip.com.  If your appeal is unsuccessful, you can file a complaint with the relevant body in your state, including:

• Washington State Attorney General at www.atg.wa.gov/file-complaint
• Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/

How to Contact Us

Please email privacy@getquip.com directly with any questions or concerns you may have about your Consumer Health Data Privacy or this Notice.  You can also contact us at 

quip
45 Main Street, Suite 630
Brooklyn, NY 11201
ATTN:  Privacy