# Consumer Health Data Privacy Policy

> Washington Consumer Health Data Privacy Policy     DRAFT    Effective Date  March 31 2024    This Washington Consumer Health Data Privacy Policy WA Health 

Source: https://support.zwift.com/en_us/consumer-health-data-privacy-policy-BkyaPjWx0

Last updated: 2024-04-08T20:51:47.814Z

# Washington Consumer Health Data Privacy Policy

Effective Date:  March 31, 2024 

This Washington Consumer Health Data Privacy Policy (“WA Health Policy” and “Policy”) applies to the “consumer health data” Zwift, Inc. (“Zwift”, “us”, “our”) collects about Washington state residents and others (“Washington consumers”) who may be subject to the Washington My Health My Data law (“Washington MHMD Act”). 

It applies to Washington consumers when acting in their individual capacities, and does not apply to Washington consumers when they are acting in their employment capacities (including as job applicants) or when acting as representatives of entities with whom we do business (e.g., vendors, suppliers).  

As used in this policy, “consumer health data” means personal information that is linked or reasonably linkable to a Washington consumer and that identifies their past, present, or future physical or mental health status, consistent with the definition of “consumer health data” under the Washington MHMD Act. 

**Consumer Health Data That We Collect – Categories** 

We collect the following categories of consumer health data: 

*   Vital signs and measurements that Zwift users choose to input or track wen using our platform or devices, such as heart rate, power output when riding, and weight

**Consumer Health Data That We Collect – Purposes**  

We collect and use consumer health data for the following purposes: 

*   To provide our services 
*   To manage our relationship with our customers, including through customer service or to respond to inquiries about our services 

**Sources of Consumer Health Data**

We collect consumer health data from Zwift users when they choose to track and upload to our platform their consumer health data.   

**Consumer Health Data We May Share With Third Parties or Affiliates**

Consistent with the definition of “sharing” under the Washington MHMD Act, we may share consumer health data with third parties as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities, to private attorneys who issue subpoenas or otherwise serve us with legal process and, to the extent required, the individuals or entities they represent.  

We do not otherwise share consumer health data with third parties and do not share consumer health data with affiliates. 

**Consumer Rights Under Washington MHMD Act**

Washington consumers have the following rights with respect to their consumer health data: 

*   Right to Know:  The right to confirm whether we are collecting, sharing or selling their consumer health data
*   Right to Access:  The right to obtain a copy of their consumer health data 
*   Right to Know Third Parties:  The right to obtain a list of all third parties and/or affiliates with whom we have shared or sold their consumer health data
*   Right to Delete:  The right to request that we delete their consumer health data 

Additionally, to the extent consent has been obtained to collect or share consumer health data, the right to withdraw consent. 

To exercise these rights, please reach out to [privacy@zwift.com](mailto:privacy@zwift.com).  We may require additional information to authenticate that you made the request(s).  If we are unable to authenticate the request(s) using commercially reasonable efforts and by asking for additional information, we will not be able to comply with the request(s).  

We will respond to such requests within 45 days from when we receive your request.  In some circumstances, we may need additional time to process your request.  If we expect your request is going to take us longer than normal to fulfill, we will let you know.

If your request is denied, you may appeal that decision as specified in our letter or denial. We will process and respond to your appeal within the time permitted by the Washington MHMD Act.

**Material Changes to Policy** 

We may change this Policy from time to time and will notify you by a notice on our website and in this Policy of material changes. 

**Contact Us**

If you have questions about this Policy or want to obtain more information about our privacy practices, please contact us at [privacy@zwift.com](mailto:privacy@zwift.com).