Washington Residents - Consumer Health Privacy Notice

Consumer Health Data Privacy Policy 

This notice supplements the Alto Pharmacy Privacy Policy and applies to personal information defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA). 

This notice does not apply where an exception or exemption applies such as with respect to protected health information under the Health Insurance Portability and Accountability Act (HIPAA).

Consumer Health Data We Collect

Depending upon which Alto Services you use and how you use them, we may collect certain personal information that may be deemed “consumer health data” under the MHMDA. Examples of consumer health data we may collect include:

• Information about your health-related conditions, treatment, medications, diseases, diagnosis, diagnostic testing, sexual health, reproduction, bodily functions, vital signs, symptoms, and health-related measurements. We may collect such information through your navigation of our website, surveys or other communication with you.

• Use or purchase of prescribed medication. 

• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. 

• Data that identifies a consumer seeking health care services. 

• Biometric data. For example, facial images captured via cameras when you enter our Pharmacy and voice recordings if you call Alto.

• Inferences or derived information based on the information we collect about you. 

Sources of Consumer Health Data

We may collect consumer health data from you as a result of your interaction with or use of our Services, including automatically when you visit Alto’s website, from third parties, and from publicly available sources.

Why We Collect and Use Consumer Health Data

We collect and use consumer health data to provide the services and products you requested or authorized.  This may include delivering and operating the Services and their features, personalization of Services, 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).

Sharing of Consumer Health Data

We may share the categories of consumer health data described above for the purposes outlined in this notice.

Third Parties With Which We Share Consumer Health Data

We may share consumer health data with our data processors, service providers and contractors who assist us in providing the products and services you requested or authorized. These companies may use the data only as permitted by our contracts with them. 

We may also share consumer health data: (i) with your consent, (ii) in connection with a merger, acquisition, bankruptcy, or similar transition of assets to a third party, (iii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable law.

Rights Related to Consumer Health Data

MHMDA provides certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions.

You can request to exercise your rights by submitting your request either to privacy@alto.com or by calling 1 (800) 874-5881 and leaving a message for our Privacy Officer. There may be certain exceptions that apply to your request.

If your request to exercise a right under the MHMDA is denied, you may appeal that decision by contacting our Privacy Officer at privacy@alto.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.