Washington Consumer Health Data Privacy Policy
This Consumer Health Data Privacy Policy describes how Clover Podiatry (“we,” “us,” or “our”) collects, uses, discloses, and protects Consumer Health Data under the Washington My Health My Data Act (RCW 19.373). This policy supplements the information contained in Clover’s Privacy Policy.
Note: Protected Health Information (PHI) created or maintained during clinical treatment in our office or through our Electronic Health Record (EHR) system is governed separately by our HIPAA Notice of Privacy Practices, provided to all new patients in clinical onboarding.
Categories of Consumer Health Data We Collect
The data we collect depends on the context of your interactions with Clover Podiatry, the choices you make (privacy settings), the products you use, and applicable law. We may collect the following categories of Consumer Health Data with your consent or to the extent necessary to provide a product or service:
- Digital Engagement Data: Internet Protocol (“IP”) addresses, unique device identifiers, web browser details, referring URLs, search terms.
- Appointments & Interaction: Dates of visits or requests, engagement with online scheduling tools, and responsiveness to digital communications.
- Inferred Health Data: Information derived from your browsing behavior, search interactions, or appointment timing that infers an interest in specific conditions or treatment options.
- Individual health conditions or treatments
- Data that identified you are seeking health care services
Sources of Consumer Health Data
We collect Consumer Health Data from the following sources:
- Directly From You: When you request an appointment, submit digital contact forms, or interact with our patient portal.
- Automatically: When you visit our website, through cookies, analytics scripts, and pixel technologies (subject to your explicit consent).
Purposes for Collecting and Using Consumer Health Data
We only collect and use Consumer Health Data for the purposes described here. Primarily, we collect and use this data as reasonably necessary to communicate with you and provide products and services. We may also use consumer health data for the following purposes:
- Essential Clinical & Website Operations: Operating our website, managing the patient portal, and delivering requested healthcare communications.
- Personalized Communications & Recall Reminders (With Explicit Consent): Utilizing engagement indicators and appointment timing to send personalized email or SMS communications, foot health education, and routine check-up reminders.
- Targeted Content & Analytics (With Explicit Consent): Utilizing browsing interactions to measure website performance, understand service interest, and deliver relevant educational content and digital advertisements.
Sharing and Disclosure of Consumer Health Data
We do not sell Consumer Health Data. We only share Consumer Health Data with third parties under the following conditions:
- Service Processors: We disclose data to trusted technical service providers (e.g., website hosting platforms, encrypted CRM/intake systems, and communication vendors) who process data strictly on our behalf pursuant to contractual security agreements.
- Third-Party Analytics & Marketing Partners: With your explicit opt-in consent through our website consent controls, we may share hashed digital engagement metrics with analytics and advertising platforms to measure digital outreach effectiveness.
- Legal Requirements: We may disclose data if required by law, subpoena, or valid court order.
Your Washington Privacy Rights
Under RCW 19.373, you have the following rights regarding your Consumer Health Data:
- Right to Confirm & Access: You have the right to confirm whether we are collecting, using, or sharing your Consumer Health Data and to request access to that data.
- Right to Withdraw Consent: You have the right to withdraw your consent for the collection, processing, or sharing of your Consumer Health Data at any time.
- Right to Delete: You have the right to request that we permanently delete your Consumer Health Data and direct our service processors to do the same.
- Right to Non-Discrimination: We will never deny care, alter pricing, or discriminate against you for exercising your privacy rights.
How to Exercise Your Rights
- Marketing Opt-Out: You may opt out of promotional emails by clicking “Unsubscribe” in any email or replying “STOP” to SMS messages.
- Data Access or Deletion Requests: To submit a formal request to access or delete your Consumer Health Data, please complete the form at https://www.cloverpodiatry.com/contact/. We will verify your identity and respond within 45 days.