PURE’S CONSUMER HEALTH DATA PRIVACY POLICY

We have adopted this Consumer Health Data Privacy Policy (the “Policy”) to comply with the Washington and Nevada consumer health data laws. This Policy describes how certain information, called “consumer health data,” may be used and disclosed by Online Classifieds AG, Baarerstrasse 8, 6300 Zug, Switzerland, CHE-274.401.166, dba PURE (“PURE,” “we,” “our,” or “us”), and how you can exercise your rights with respect to this information. This Policy supplements our Privacy Policy, and in the event of a conflict between our Privacy Policy and this Policy, this Policy will prevail as to consumer health data of Washington and Nevada residents.

1. Collection of consumer health data

Consumer health data includes 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. We do not intentionally collect consumer health data, nor do we use any data we collect to identify or infer your past, present, or future physical or mental health status. However, in light of the broad definitions of “consumer health data” in Washington and Nevada, the information we collect from or about you may sometimes fall under this category. 

Consumer health data may include the following types of personal information:

• Information about health conditions, treatments, diseases, or diagnosis;
• Social, psychological, behavioral, and medical interventions;
• Health-related surgeries and procedures;
• Use or purchase of prescribed medication;
• Bodily functions, vital signs, or symptoms, or measurements;
• Gender-affirming care information;
• Reproductive and sexual health information;
• Biometric data;
• Genetic data;
• Precise location information that could reasonably indicate a consumer’s attempt to acquire or receive health services or supplies;
• Data that identifies a consumer seeking health care services; or
• Other information that may be used to infer or derive data related to the above health information.

The purpose of collecting data from you is to provide you with the services you requested and help you connect to other PURE app Users.

2. Use of consumer health data

We may use the consumer health data we collect in one or more of the following ways:

• To provide a product or service that you have requested from us;
• To provide you with customer service and to respond to your inquiries, including investigating and addressing any concerns you may need our assistance with; 
• To create, maintain, customize, confirm, and secure your profile information (this may include your choice to use our Photo Verified feature if you wish to confirm that the submitted photos reflect your real appearance);
• To prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under Washington state law or federal law; preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action that is illegal under Washington state law or federal law;
• To protect the confidentiality, integrity and accessibility of your data;
• To perform data analytics and quality control;
• To perform research, product development, testing, and analysis, including to improve our website and services;
• To conduct internal investigations and audits, investigate grievances and suspected violations of our policies;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To comply with any applicable laws, regulations and statutory requirements.
• To exercise and defend our legal rights;
• To protect your safety or the safety of others and
• To evaluate or conduct a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us is among the assets transferred.

3. Sources of consumer health data

We obtain the categories of consumer health data listed above from the following categories of sources:

• Directly from you. For example, when you wish to share your gender-affirming history with other PURE app users, or when you choose to use our Photo Verified feature to confirm that your submitted photos reflect your real appearance.
• Automatically as you navigate through our website. Information collected automatically may include IP addresses, device identifiers, and information collected through cookies, and other tracking technologies.

4. Sharing consumer health data

We do not sell your consumer health data. We may share any consumer health data you choose to disclose on your profile in order to provide you with the services you requested from us or to comply with the law. We may share your consumer health data with the following categories of third parties: 

• Other PURE app Users. You share information with other Users when you voluntarily disclose information about yourself on PURE for other Users to see (e.g., your public profile).
• Professional service providers (such as IT service providers, analytic services providers, advertising partners), where enabling access to data helps us provide our services and operate our business.
• Parties to a corporate transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by us is among the assets transferred.
• Government, regulatory, and law enforcement authorities, if required by law, protect the safety of you or others, or to assist in the prevention or detection of a crime.
• Parties to litigation.

5. Exercising your rights

Subject to limited exceptions, the health data privacy laws provide Washington and Nevada residents (as well as individuals whose consumer health data is collected in Washington and Nevada) with certain rights regarding consumer health data, including the right to access, to withdraw consent, and to delete data. You may exercise your rights by contacting us at [email protected]. In your request, you must (1) indicate which right you would like to exercise, and (2) provide sufficient information to verify your identity. The type of information you may need to provide to prove that you are who you say you are may depend on the sensitivity of information requested.  

If your request is denied, you may appeal our decision in writing by contacting us at [email protected]. If your appeal is unsuccessful, we will provide you with an online mechanism or another method through which you may contact the Attorney General to submit a complaint.

6.  Changes to this Policy

We reserve the right to amend, modify and delete sections of this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on the website and update the effective date accordingly. You are responsible for reviewing this Policy periodically to make sure you are aware of any changes.

7.  Contact 

If you have any concerns or require any information regarding the PURE or PURE’s practices described in this Policy, please contact us [email protected].

Alternatively, you can write to:

Online Classifieds AG
Baarerstrasse 8
6300 Zug
Switzerland