Consumer Health Policy
Effective Date: November 13, 2024
This Consumer Health Data (CHD) Privacy Policy applies to CHD, as that term has been defined by applicable states and federal laws. This policy supplements Coterie’s Privacy Policy. This CHD Privacy Policy describes Coterie’s (“we”, “us”, or “our”) practices regarding the collection, use, sharing and disclosure of CHD. Any capitalized terms not defined in this CHD Privacy Notice shall have the meanings given to them in Coterie’s Privacy Policy. Importantly, this CHD Privacy Policy does not supersede, replace, or otherwise amend Coterie’s Privacy Policy.
Generally, CHD 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. CHD does not include information that does not qualify as CHD under the relevant state and federal regulations, for example, Washington’s My Health My Data Act (MHMDA”). CHD does not include protected health information subject to the federal Health Insurance Portability and Accountability Act and related regulations (“HIPAA”).
The Categories of CHD Coterie Collects
We Collect the below categories of Consumer Health Data from Consumers.
- Name, Date of Birth, Weight, Height
- General information of skin conditions;
- Use or purchase of over-the-counter skin medication;
- Precise location information that could reasonably indicate a resident's attempt to acquire or receive health related supplies;
- Data that identifies a resident seeking health care services;
- Any inferences of the above categories of health data derived or extrapolated from non-health information.
We use the above-mentioned categories of CHD for the following purposes:
- Perform the services or providing the goods reasonably expected by an average consumer who requests those goods or services;
- Ensure security and integrity of our website(s) and services to the extent the use of the CHD is reasonably necessary for these purposes;
- Prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted CHD;
- Resist malicious, deceptive, fraudulent, or illegal actions directed at us and prosecute those responsible for those actions;
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a Consumer's current interaction with us.
- To make personalized suggestions about other Coterie products you may like.
- Perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf; and
- Undertake activities to verify or maintain the quality or safety of a product or service that is owned, manufactured by, manufactured for, or controlled by us, and to improve, upgrade, or enhance the product or service that is owned, manufactured, manufactured for, or controlled by us.
- Exercising and defending legal claims.
Otherwise accomplishing our business purposes and objectives.
The Categories of Sources from Which We Collect CHD:
- We Collect CHD directly from you, as you enter the information on our website;
- Authorized/legal representatives, family members, and caregivers;
- Consumer reporting agencies and other Third Parties who verify the information you provide;
- Your mobile devices, with your permission, upon downloading and when you visit or interact with our websites, applications, and online platforms;
- Your mobile devices and other internet-connected devices with your permission when you use these devices and relevant applications;
- Your computer and mobile devices (automatically) when you visit or interact with our websites, applications, and online platforms;
- Cookies, web beacons, and similar technologies (automatically) when you visit our websites or Third Party websites;
- Advertising partners who provide digital marketing services;
- Third Parties and Processors who provide website and online security services;
- Third Parties and Processors who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records;
- Third Parties and Processors who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier;
- Third Parties and Vendors that provide access to information you make publicly available, such as social media platforms;
- Third Parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators;
- Third Parties who assist with fraud prevention, detection, and mitigation; and
- Third Parties and Processors who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners.
- We also draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.
The Categories of CHD that We Share:
- We do not sell your CHD.
- We share all of the categories of CHD that we Collect, as disclosed above above in Section 1, for the purposes listed in Section 2.
Third Parties and Affiliates with Whom We Share CHD:
- Third Parties that help administer, manage, and analyze our programs and services;
- Third Parties with whom we have joint marketing and similar arrangements;[RB1]
- Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention;
- Third Parties who deliver our communications, such as the postal service and couriers;
- Third Parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers;
- Third Party network advertising partners;
- Third Parties who assist with our information technology and security programs;
- Third Parties who assist with fraud prevention, detection, and mitigation;
- Third Parties as reasonably necessary to facilitate a merger, sale, joint venture or collaboration, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock;
- Third Parties as necessary to complete transactions and provide our products/services, including delivery companies, agents, and manufacturers;
- Consumer reporting agencies;
- Our lawyers, auditors, and consultants; and
- Legal and regulatory bodies and other Third Parties as required by law.
How to Exercise Your Rights with Respect to your CHD
To exercise your rights with respect to your CHD, depending on your state of residence, you may contact us at any time through any of the following methods.
Coterie Baby, Inc.
Attn: Legal – Privacy
160 Varick Street
Floor 3 Suite 103
New York, NY 10013
1-866-I-OPT-OUT(1-866-467-8688) and enter Service Code 2016#. (Calls from USA only)
Review & Revision of CHD
If you would like to review and/or revise your CHD, you may submit a request to us via any of the methods listed in our CHD Privacy Policy. We will respond to your requests to exercise your rights in accordance with applicable law, but in any case no later than 45 days after receiving your request. We may extend this period up to 45 days only where doing so is permitted under applicable law.
Changes to this CHD Privacy Notice
We reserve the right to amend this CHD Privacy Notice at our discretion and at any time. When we make material changes to this CHD Privacy Notice, we will notify you by posting an updated CHD Privacy Notice on our websites, including the effective date of such updates.
Third Party Collection of CHD
We limit Third Party Collection of CHD over time and across different websites or online services when the Consumer uses our websites or online services. We do this by ensuring that entities whose cookies, web beacons, pixels, and other online trackers we use on our websites and online services are our Vendors under applicable U.S. Privacy Laws and under CHD privacy laws. Nonetheless, please note that Third Parties may still be able to Collect CHD from you over time and across different websites depending on your browser, browser add-ons, and associated permissions you set on your device. This Collection of CHD by those Third Parties is unrelated to Coterie's Collection of CHD from you, and we encourage you to view those Third Parties' privacy notices for more information about their Processing of CHD and the methods they provide to allow you to opt out of such Processing.