Consumer Health Data Privacy Notice

Last Modified: December 18, 2024

OVERVIEW

This notice supplements the Privacy Notice and applies only to “consumer health data” subject to the Washington State My Health My Data Act (MHMDA).

This notice describes the collection, use, and disclosure practices with respect to Family First Life USA (“we,” “us”, “our,” or the “Company”) and its website, familyfirstlifeusa.com, and any other websites or platforms that the Company may create in the future (the “Platform”)

Individuals that are residents of Washington or individuals with consumer health data that has been collected in Washington should review this notice.

CONSUMER HEALTH DATA WE COLLECT / SOURCES OF CONSUMER HEALTH DATA

The table below details the categories of Consumer Health Data that we may collect or obtain through the operation of the Platform and services we provide. In addition to the sources listed below, we may collect this information from third-party service providers or vendors. We may also infer certain information about you based on information provided from any of the sources listed below.

Category (as defined by MHMDA)	Examples & Sources
Health conditions, diseases, treatment, or diagnoses	Consumer’s health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product. For example, notes about a Consumer may state that the Consumer has diabetes, as is relevant for an application for a life insurance product.
Health-related surgeries or procedures;	Consumer’s health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product.
Use or purchase of prescribed medication	Consumer’s health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product.
Diagnoses or diagnostic testing, treatment, or medication	Consumer’s health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product.
Data that identifies a consumer seeking health care services;	Consumer’s health information provided in the course of discussions with an Agent or representative, which is relevant to the processing of an application for an insurance product.
Biometric Data	Audio recordings of Consumer conversations with representatives and Agents in connection with inquiries regarding insurance products. We may also have access to video snippets of user website activity evidencing consent to be contacted. This information is collected from Lead Vendors, Agents, insurance carriers, and agencies.

USE OF CONSUMER HEALTH DATA

We may use or disclose the consumer health data that we collect for one or more of the following purposes:

Provide our products and services;
Operate the Platform
Communicate with you regarding the Platform;
Contact Consumers through our employed agents regarding insurance products in which the Consumer expressed interest;
Address users’ and Consumers’ inquiries;
Process transactions;
Tailor the content and information that we may send or display to you;
Analyze use of our products and services;
Develop new products and services;
Comply with legal obligations;
Protect our rights, property, and safety or the rights, property, and safety of others; and
Evaluate or conduct a merger, 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 personal information held by us about our customers is among the assets transferred. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Notice, under the circumstances described in this paragraph.

We may collect, use, or disclose of consumer health data 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.

SHARING CONSUMER HEALTH DATA

We may disclose all categories of consumer health described above in “Consumer Health Data We Collect” to the third parties listed below for the purpose of facilitating the sale of insurance products to individuals who are interested in purchasing such products. We share consumer health data with:

With Consumer concerning the health data;
With our clients (i.e. insurance carriers so that they can provide coverage options based on the information the consumer provides);
With data analytics providers;
With service providers that help us provide our services and operate our business; and
With our affiliates.

YOUR PRIVACY RIGHTS

As a Washington resident, or an individual with consumer health data collected in Washington, you have the rights listed below. To exercise your privacy rights, please click here.

Consumer Right	Description
Right to Confirm Processing of Consumer Health Data	You may request confirmation of whether Company is collecting, sharing, or selling your consumer health data.
Right to Access Consumer Health Data	You may request access and obtain a copy of the specific pieces of consumer health information we have collected about you, including a list of all third parties and affiliates with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties.
Right to Withdraw Consent to Collect and Share Consumer Health Data	You may request to withdraw consent from our collection (i.e. use) and sharing (with third parties and affiliates) of your consumer health data.
Right to Delete Consumer Health Data	You may request deletion of your consumer health data.
Right to Request to Appeal Denial	You may request Company to reconsider a denial of a consumer health data request. If your appeal is unsuccessful, you can raise a complaint with the Washington State Attorney General at https://www.atg.wa.gov/file-complaint.

EXERCISING YOUR PRIVACY RIGHTS

Process

Description

Authentication

In order to protect your consumer health data from unauthorized access or deletion, we may require you to verify your account credentials before you can submit a privacy rights request. If you do not have an account with us, or if we suspect that your account has been accessed without your authorization, we may ask you to provide additional Personal Data for verification.

We are legally obligated to verify your identity when you submit a request. We may request additional information from you to verify your identity. If you submit a request to delete your Personal Data, you will also be required to confirm the deletion request by email.

If we are subsequently unable to confirm your identity, we may refuse your privacy rights request.

Use of Authorized Agents

Only you may request related to your consumer health data, it does not allow any authorized individuals to make a request on your behalf.

To exercise any of these rights, please click here.

UPDATES TO THIS PRIVACY NOTICE

We may revise this Consumer Health Data Privacy Notice from time to time. If we make material changes to this Consumer Health Data Privacy Notice, we will notify you by email or by posting a notice on our Platform prior to or on the effective date of the changes. By continuing to access or use the Platform after those changes become effective, you acknowledge the revised Consumer Health Data Privacy Notice.