This Consumer Health Data Privacy Policy applies to personal information defined as “Consumer Health Data” (CHD) subject to the Washington State My Health My Data Act (MHMDA) or other applicable state consumer health privacy laws.
This Consumer Health Data Privacy Policy (CHD Privacy Policy) supplements our general Privacy Policy. In a conflict involving CHD between those two policies, the CHD Privacy Policy shall control, subject to applicable law.
If Consumer Health Data meets the definition of protected health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA), then the HIPPA provisions in our general Privacy Policy will govern the use, disclosure, and processing of any such PHI.
Capitalized terms in our Privacy Policy will have the same meaning in this CHD Privacy Policy.
Our “Services” include the Pomegranate Health website located at www.joinpomegranate.com, the Pomegranate Health mobile application, membership services, personal healthcare navigation services, wellness services, communication services, facilitation of access to telehealth services, certain on-demand app and video-based telehealth services, and other technology-enabled or personal services provided by Pomegranate Health or its affiliate.
Examples of Consumer Health Data we collect may include:
- Data that identifies a consumer seeking health care services.
- Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments (including surgeries, procedures, medications, or other interventions).
- Information collected through our weight loss, longevity, men’s health, women’s health, hair, skin and nutrition intakes.
- Sexual and reproductive health, such as information about your sex life, reproductive health, and/or sexual orientation.
- Measurements of bodily functions, vital signs, or characteristics to measure the effectiveness of the products and treatment.
- Genetic data, such as that included in medical history collected by Pomegranate Health.
- Geolocation information that could reasonably indicate your attempt to acquire or receive health services or supplies.
- Account profile information, such as a username or account number in combination with a password, security or access code, or other credential that allows access to an account; a redemption code.
- Biographical details; links to your profiles on social networks; information about your interests and preferences; and any other information that you add to your account profile.
- Payment data such as your credit card number, financial account information, and other payment details.
- Transactional data, such as information relating to or needed to complete your orders on or through the Services, including order numbers and transaction history with our business customers.
- Communications data based on our exchanges with you, including when you contact us, use the chat features, connect with our support team, complete an intake, or interact with us on social media.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content data, such as comments, questions, messages, and other content or information that you transmit, or otherwise make available on the Services, as well as associated metadata.
- Other information that may be used to infer or derive data related to the above or other health information.
As described further in our Privacy Policy, we collect Personal Information (which may include CHD) directly from you, from your interactions with Services and products, and from third parties.
When you use our Services, we may collect Consumer Health Data through certain tracking technologies, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, network activity, and location data.
- Precise geolocation data, when you authorize our mobile application to access your device’s specific location.
- Online activity data, such as pages or screens you viewed on our Services, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of tracking technologies, like cookies, and pixels.
We collect and use Consumer Health Data as reasonably necessary to provide you with the Services and any products you have requested or authorized.
The purposes of collection may include delivering, operating and securing the Services and products, personalization of certain product features, troubleshooting and improving the Services and products, and other essential business operations that support the provision of the Services and products (e.g., performance analytics, legal obligations, workforce development and research and development).
As necessary for the purposes described above, we share Consumer Health Data with the following categories of third parties:
Service providers. Vendors or agents (“processors”) working on our behalf may need to access CHD for the purposes described above, including customer service support, payment processing, or protection of our systems and Services.
Parties to a corporate transaction. We may disclose CHD as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.
Government agencies We disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.
Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, such as health care providers or our affiliates.
You may have certain rights with respect to Consumer Health Data, including:
- Right to Know. The right to know if we are collecting, using, or disclosing your CHD, to access your CHD, or to receive a list of the categories of third parties with whom we have shared your CHD.
- Right to Withdraw Consent. If we are processing your CHD based upon consent, the right to withdraw that consent.
- Right to Delete. The right to request that we delete your CHD.
You can contact us to exercise these rights. We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
If your request to exercise a right is denied, you may appeal that decision by emailing us or writing to us at the following address:
Pomegranate Health LLC
611 S Dupont Hwy STE 102
Dover, DE 19901
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, the Nevada State Attorney General at https://ag.nv.gov/complaints/file_complaint/, or other regulatory authority as applicable.
We reserve the right to modify this Consumer Health Data Privacy Policy at any time. We will notify of any changes to our privacy practices with respect to your Consumer Health Data by posting an updated notice on this page with the “Last Updated” date.
Last Updated: April 7, 2026
Due to a high influx of volume, our current turnaround time is 7–10 business days. We appreciate your patience and look forward to taking great care of you.
