Consumer Health Data Privacy Notice
Effective date: [EFFECTIVE DATE]
This Consumer Health Data Privacy Notice supplements the Everpath Privacy Policy. It describes how Everpath Advisors LLC collects, uses, discloses, and protects consumer health data.
This notice applies where consumer health-data laws apply to Everpath, including laws protecting health information that may fall outside HIPAA.
1. Consumer Health Data We May Collect
Depending on the questions presented, we may collect:
- Whether one or more applicants use prescription medication
- General prescription-count ranges
- Selected medical-condition categories
- General treatment or hospitalization information
- Tobacco-related information
- Whether someone seeking coverage falls within an applicable age category
- Coverage status or coverage needs
- Information that may permit an inference about an individual’s health or eligibility for certain products
We should not request detailed medical records, medical documents, Social Security numbers, or complete prescription histories through the initial Everpath questionnaire.
2. Sources of Consumer Health Data
We collect consumer health data directly from the person completing the questionnaire.
We may also create a neutral qualification or routing result based on the answers supplied.
3. Why We Collect and Use Consumer Health Data
We use consumer health data to:
- Present the appropriate questionnaire path
- Determine whether a request fits the general criteria for a particular route
- Identify whether further review by a licensed professional may be appropriate
- Prevent consumers from being routed toward clearly unsuitable options
- Operate, secure, and troubleshoot the questionnaire
- Comply with applicable obligations
4. How Consumer Health Data Is Disclosed
Raw medical questionnaire answers are intended to remain within Everpath’s Heyflow qualification environment.
Everpath does not intend to send raw medical answers to:
- Make
- Ringy
- TrustedForm
- Meta or other advertising platforms
- Licensed insurance agents through the initial lead payload
Licensed professionals may separately ask relevant questions during a call or approved application process.
We may disclose consumer health data to service providers that host or secure the qualification questionnaire, subject to contractual and security requirements.
We may also disclose information when required by law or necessary to protect rights, safety, and security.
5. Sale of Consumer Health Data
Everpath does not sell consumer health data.
Everpath does not use consumer health data for targeted advertising.
6. Consumer Consent
Where required, Everpath will request consent before collecting or sharing consumer health data for a new purpose.
A consumer may withdraw consent by contacting: contact@tryeverpath.com
Withdrawal does not affect processing that occurred before withdrawal.
7. Consumer Health Data Rights
Depending on applicable law, consumers may have the right to:
- Confirm whether Everpath collects, shares, or sells their consumer health data
- Access their consumer health data
- Receive a list of third parties or affiliates that received their consumer health data
- Withdraw consent
- Request deletion from active systems, archives, and backups where required
- Appeal the denial of a request
Submit a request to contact@tryeverpath.com using the subject line “Consumer Health Data Request.”
We may take reasonable steps to verify the identity and authority of the person making the request.
8. Data Retention
We retain consumer health data only for as long as reasonably necessary for qualification, security, dispute handling, and applicable legal or contractual requirements.
Where possible, raw medical answers should be deleted or deidentified when they are no longer needed.
9. Security
We use administrative, technical, and organizational safeguards intended to protect consumer health data.
Consumer health data should not be sent through ordinary email, text messages, or advertising platforms.
10. Changes to This Notice
We may update this notice when our practices, vendors, questionnaire, or legal obligations change. The effective date above identifies the current version.
11. Contact
Everpath Advisors LLC
[MAILING ADDRESS]
Email: contact@tryeverpath.com
Phone: [BUSINESS PHONE]