Privacy Policy
Last Updated: January 1, 2026
Memoir, Inc. d/b/a Chapter and its affiliates, including Chapter Medicare, LLC d/b/a Chapter Advisory, LLC, Chapter Technologies, LLC, and Quentin Cares Insurance Services Inc. (collectively “Chapter,” “Company”, “we”, “us”), provide services to educate and advise individuals regarding certain healthcare, financial, and technology matters. We also, through Chapter Advisory, LLC (doing business in California as Chapter Insurance Services), provide licensed insurance agency services to help individuals choose a Medicare benefits plan and other types of health coverage for their needs. This privacy policy (“Privacy Policy”) is designed to help you understand how we collect, use, and share your Personal Data and to help you understand and exercise your privacy rights.
This Privacy Policy applies to personal data that individually identifies you (“Personal Data”) collected from and about you in connection with your use of our websites, mobile applications, and other online and telephonic offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other online and telephonic offerings are collectively called “Services”. This Privacy Policy, supplements and is incorporated into each of our Terms of Service (which governs your use of our Services, except for Services provided by Chapter Technologies, LLC) and the Chapter Technologies Terms of Service (which governs your use of the Services provided by Chapter Technologies, LLC). If you do not agree to the applicable Terms of Service and the collection, use and sharing of your information as detailed in this Privacy Policy, please do not access or otherwise use our Services or any information or content accessible on our Services.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing Personal Data to third-party websites or applications is at your own risk.
We collect, use, share, and process Personal Data from users of our Services in several contexts as described below. This Privacy Policy does not apply to the following information:
The categories of Personal Data we collect depend on how you interact with us, our Services and the requirements of applicable laws, regulation, and official guidance. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect the following Personal Data that you provide to us.
We may collect Personal Data automatically when you use our Services:
See Section 5 below to understand your choices regarding these Technologies.
We may obtain information about you from other sources, including healthcare providers and third-party organizations and partners who provide health-related services and who authorize such information sharing. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
We use your Personal Data for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfill our contract (the Terms of Service or the Chapter Technologies Terms of Service) with you and provide you with our Services, such as:
We use your information for various administrative purposes, such as:
We may use Personal Data to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable laws, regulations, and official guidance.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking, in compliance with applicable laws and regulations.
If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Data for marketing purposes, you may contact us at any time as set forth below.
We also use your information for other purposes as requested by you or as permitted by applicable law.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
The categories of third parties with whom we may share your information are described below.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Additionally, you can turn off certain third-party targeting/advertising cookies by visiting the Network Advertising Initiative: https://optout.networkadvertising.org/ and by visiting Google: https://tools.google.com/dlpage/gaoptout.
Please note you must separately opt out in each browser and on each device. Your browser may provide you with some options regarding cookies. For more detailed information about how to disable or administer your cookie settings in your web browser, please refer to the applicable page for the browser you are using:
• Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Microsoft Edge / Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
You can withdraw your consent to allow for cookies, change your browser settings, and delete the cookies already stored on your computer at any time. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services on our website to their fullest potential.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
By using our Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
7. USERS OUTSIDE OF THE UNITED STATES
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Data in accordance with this Privacy Policy regardless of where your Personal Data is stored/accessed.
8. SOCIAL SECURITY PROTECTION POLICY STATEMENT
It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) from misuse and improper disclosure by maintaining and enforcing physical, electronic, and procedural safeguards. We prohibit unlawful disclosure of SSNs, and limit access to SSNs to our personnel who need access to SSNs in order to perform their job functions. We do not disclose SSNs to third parties except where required or permitted by law.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
Residents of California may have certain rights under §1798.83, known as the “Shine The Light” law, to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Data in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request clearly in writing to us using the contact information provided below.
In our capacity as an insurance agency, we rarely handle Personal Data that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). For services provided as part of the Chapter OTC application under Chapter Technologies, LLC and in the other limited cases where we may collect Personal Data about certain California residents subject to the CCPA, our CCPA policy, incorporated herein, applies to that Personal Data.
10. SUPPLEMENTAL NOTICE FOR WASHINGTON AND NEVADA RESIDENTS
For individuals in Washington and Nevada, please refer to our Consumer Health Data Privacy Policy, which is incorporated herein, for additional information about the processing of your Personal Data that is considered “consumer health data” as defined under those states’ laws.
You may have rights under other state consumer privacy laws, including, without limitation, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia. Please contact us at [email protected] if you have questions or would like to exercise a right under these laws.
The Services are not directed to children or individuals under the age of 18. Children under the age of 18 are strictly prohibited from using the Services. We do not knowingly collect Personal Data from children.
Protecting children’s privacy online is very important to us. If you access or use the Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Services under applicable state and federal laws.
If you are a parent or guardian and wish to review information that you believe we may have unintentionally collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with Personal Data in violation of applicable law, we will delete any Personal Data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.
13. CHANGES TO OUR PRIVACY POLICY
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
14. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Memoir, Inc. d/b/a Chapter
19 Union Square West, 12th Floor
New York, NY 10003
Supplemental Notice for California Residents - CCPA Policy
Last Updated: January 1, 2026
As discussed in our Privacy Policy, Memoir, Inc. d/b/a Chapter and its affiliates (collectively, as defined in the Privacy Policy, "Chapter," "Company," "we," and "us") rarely handle Personal Data that is considered “personal information” as defined by and subject to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) in our capacity as an insurance agency. For services provided as part of the Chapter OTC application offered by Chapter Technologies, LLC and in the other limited cases where we may collect Personal Data about certain California residents subject to the CCPA, this CCPA Policy ("Policy") explains the rights of California residents regarding the collection, use, sale, and sharing of their Personal Data. This Policy is in addition to our Terms of Service and Privacy Policy. All references to "Chapter," "Company," "we," and "us" in this Policy have the meanings ascribed to them in the Privacy Policy.
This Policy does not apply to the following types of information:
In the preceding 12 months, we have collected the following categories and specific types of Personal Data:
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Categories of Personal Data We Collect |
Categories of Third Parties with Whom We Disclose Personal Data for a Business Purpose |
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Identifiers (e.g., your real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information (“Sensitive Information”) |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Characteristics of protected classifications under California or federal law |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Website, application, or advertisement) |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Geolocation data |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Professional or employment-related information |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
· Affiliates and subsidiaries · Third party service providers · For legal, security, and safety purposes · In connection with a corporate transaction · Entities to which you have consented to the disclosure
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We collect most of this Personal Data directly from interactions with you through our Services. However, we may also collect information from the following categories of sources:
We collect consumer Personal Data for the following business purposes:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your Personal Data for and our reasons for doing so:
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What we use your Personal Data for |
Our reasons |
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To provide services to you |
For the performance of services to you or to take steps at your request before providing services |
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To prevent and detect fraud against you or Chapter |
For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
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Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
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Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies |
To comply with our legal and regulatory obligations |
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Ensuring business policies are adhered to, e.g., policies covering security and internet use |
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
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Operational reasons, such as improving efficiency, training, and quality control |
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
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Ensuring the confidentiality of commercially sensitive information |
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
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Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures |
For our legitimate interests or those of a third party |
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Preventing unauthorized access and modifications to systems |
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
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Updating and enhancing customer records |
For the performance of services to you or to take steps at your request before providing services To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
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Statutory returns |
To comply with our legal and regulatory obligations |
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Ensuring safe working practices, staff administration and assessments |
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
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Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings. |
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
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External audits and quality checks, e.g., for accreditations and the audit of our accounts |
For our legitimate interests or those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
In the preceding 12 months, we have disclosed consumers’ Personal Data with:
We only allow our service providers to handle your Personal Data if we are satisfied that they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your Personal Data to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some Personal Data with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
In the preceding 12 months, we have sold or shared the following categories of Personal Data:
In the preceding 12 months, we have disclosed the following categories of Personal Data for a business purpose:
We will keep your Personal Data while you have an account with us or while we are providing services to you. Thereafter, we will keep your Personal Data for as long as is necessary:
We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data.
You have the right under the CCPA and CPRA, and certain other privacy and data protection laws, as applicable, to exercise free of charge:
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Disclosure of Personal Data We Collect About You |
You have the right to know, and request disclosure of: • The categories of Personal Data we have collected about you, including sensitive Personal Data; • The categories of sources from which the Personal Data is collected; • Our business or commercial purpose for collecting, selling, or sharing Personal Data; • The categories of third parties to whom we disclose Personal Data, if any; and • The specific pieces of Personal Data we have collected about you.
Please note that we are not required to: • Retain any Personal Data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or • Provide the Personal Data to you more than twice in a 12-month period. |
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Disclosure of Personal Data Sold, Shared, or Disclosed for a Business Purpose |
In connection with any Personal Data we may sell, share, or disclose to a third party for a business purpose, you have the right to know: • The categories of Personal Data about you that we sold or shared and the categories of third parties to whom the Personal Data was sold or shared; and • The categories of Personal Data that we disclosed about you for a business purpose and the categories of persons to whom the Personal Data was disclosed for a business purpose.
You have the right to opt-out of the sale of your Personal Data or sharing of your Personal Data for targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your Personal Data, we will refrain from selling or sharing your Personal Data, unless you subsequently provide express authorization for the sale or sharing of your Personal Data.
To opt-out of the sale or sharing of your Personal Data, send an email to: [email protected]. You can also scroll to the bottom of this page and click the link to manage your cookies preferences. |
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Right to Limit Use of Sensitive Personal Data |
You have the right to limit the use and disclosure of your sensitive Personal Data to the use which is necessary to: · Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; · To perform the following services: o (1) Helping to ensure security and integrity to the extent the use of the consumer’s Personal Data is reasonably necessary and proportionate for these purposes; o (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, if the consumer’s Personal Data is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business; o (3) Performing services on behalf of the business, 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 behalf of the business; and o (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and As authorized by further regulations. You have a right to know if your sensitive Personal Data may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To opt-out of the sale or sharing of your Personal Data, send an email to: [email protected]. You can also scroll to the bottom of this page and click the link to manage your cookies preferences. |
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Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: • Delete your Personal Data from our records; and • Direct any service providers or contractors to delete your Personal Data from their records. • Direct third parties to whom the business has sold or shared your Personal Data to delete your Personal Data unless this proves impossible or involves disproportionate effort.
Please note that we may not delete your Personal Data if it is reasonably necessary to: • Complete the transaction for which the Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; • Help to ensure security and integrity to the extent the use of the consumer’s Personal Data is reasonably necessary and proportionate for those purposes; • Debug to identify and repair errors that impair existing intended functionality; • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; • Comply with the CCPA; • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; • Comply with an existing legal obligation; or • Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information. |
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Right of Correction |
If we maintain inaccurate Personal Data about you, you have the right to request us to correct that inaccurate Personal Data. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Data. |
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Protection Against Retaliation |
You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: • Deny goods or services to you; • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; • Provide a different level or quality of goods or services to you; or • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. |
If you would like to exercise any of your rights as described in this Policy, you may email us at: [email protected].
Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly by email, you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
Consumer Health Data Privacy Policy
Last updated: January 1, 2026
This notice supplements our Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA) and Nevada’s Consumer Health Data Privacy Law.
Please note that data practices concerning PHI we collect are described in the terms and privacy disclosures specific to those services.
As described in the Privacy Policy, the data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services and features you use, your location, and applicable law.
Examples of consumer health data may include:
As described further in our Privacy Policy, we collect personal data (which may include consumer health data) directly from you, from your interactions with our Services, from third parties, and from publicly available sources.
We collect and use consumer health data for the purposes described in our Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the Services you have requested or authorized. This may include delivering and operating the Services and their features, personalization of certain Service features, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the Services, and other essential business operations that support the provision of the Services (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).
We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law – for example, for advertising or marketing purposes. See our Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.
As described in our Privacy Policy, we may create aggregate/de-identified data from the information we collect through the Services and our disclosure of such aggregate/de-identified data is at our discretion.
We may share your consumer health data for the purposes described in our Privacy Policy. In particular, we may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any Service you have requested or authorized, as described above.
We share your Personal Data with third parties when you tell us to do so. If you make a purchase through the Chapter OTC application, we will share Personal Data about the transaction as necessary to process the payment, including protection against fraud. We may disclose Personal Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.
As necessary for the purposes described above, we share consumer health data with the following categories of third parties:
The MHMDA and Nevada Consumer Health Data Privacy Law provide certain rights with respect to consumer health data, for example rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. Please refer to our Privacy Policy for more details on ways to request to exercise such rights. If you want to access or control consumer health data processed by us that is not available via those tools or directly through the Services you use, you can always contact us at [email protected].
If your request to exercise a right under the MHMDA or Nevada Consumer Health Data Privacy Law is denied, you may appeal that decision by contacting our Privacy Officer at [email protected]. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Nevada State Attorney at https://ag.nv.gov/Complaints/File_Complaint/ or Washington State Attorney General at https://www.atg.wa.gov/file-complaint, as applicable.