Washington My Health My Data Act

Washington Consumer Health Data Privacy Policy

Effective September 9, 2026

This Washington Consumer Health Data Privacy Policy supplements the Thymos Health Privacy Policy and applies to Consumer Health Data subject to the Washington My Health My Data Act ("MHMDA") that is collected by Thymos Health, Inc. or Thymos Provider Group, PC.

1. Important Scope and Healthcare Exemptions

Much of the health information maintained by Thymos is governed by HIPAA, Washington healthcare privacy law, or other healthcare laws and is therefore exempt from the MHMDA.

The MHMDA generally does not apply to:

This Policy applies only to Consumer Health Data that is not exempt and is otherwise subject to the MHMDA.

For PHI and medical records, please review the Thymos Provider Group Notice of Privacy Practices and the main Thymos Health Privacy Policy.

2. Consumer Health Data We May Collect

Depending on how you interact with Thymos, non-exempt Consumer Health Data may include:

Health Interests and Healthcare-Seeking Activity

Information indicating or potentially suggesting that an individual:

Health Conditions and Health-Related Information

Where not otherwise exempt, this may include information relating to:

Derived or Inferred Consumer Health Data

Consumer Health Data may include health information derived or inferred from other data, including through analytics, algorithms, or interaction with health-related content.

Location Information

Thymos does not currently collect continuous or background precise GPS location through its mobile application.

A patient may manually provide a physical location where needed for telehealth care.

If location information were used in a manner that constitutes Consumer Health Data under Washington law and is not otherwise exempt, this Policy would apply.

3. Why We Collect and Use Consumer Health Data

Where the MHMDA applies, we may collect and use Consumer Health Data to:

We collect Consumer Health Data where:

4. Sources of Consumer Health Data

We may obtain Consumer Health Data from:

5. Consumer Health Data We May Share

Where information is subject to MHMDA, categories of Consumer Health Data that may be shared as necessary to provide requested services or with consent where required may include:

Much of Thymos's actual clinical sharing occurs within HIPAA-regulated healthcare activities and is therefore outside the scope of this Policy.

6. Categories of Recipients and Specific Affiliates

Where Consumer Health Data subject to the MHMDA is shared as necessary to provide a requested service or with appropriate consent, recipients may include:

Specific Thymos affiliates that may receive Consumer Health Data are:

Thymos Health, Inc.
Thymos Provider Group, PC

Processors are contractually required to process covered information consistently with applicable law and Thymos's instructions.

7. Analytics and Advertising

Public portions of the Thymos website may use analytics and infrastructure services to understand website performance and use.

Thymos does not configure these technologies to capture the values users enter for fields such as first name, last name, email address, telephone number, or state on the Autoimmune Guide form.

Thymos does not permit advertising or analytics trackers in the clinical mobile experience once a person begins:

Thymos does not upload patient lists or health-derived prospect lists to advertising platforms for Customer Match, Custom Audiences, lookalike audiences, retargeting, or similar audience-building.

Thymos does not send advertising platforms conversion events reflecting disease-specific page visits, Autoimmune Guide downloads or submissions, commencement of intake, or similar health-derived activities.

8. Sale of Consumer Health Data

Thymos does not sell Consumer Health Data.

Thymos does not exchange Consumer Health Data for money or other valuable consideration in a manner that constitutes a sale under the MHMDA.

If this practice were ever to change, Thymos would first implement the separate written authorization process required by applicable law.

9. Global Privacy Control

Thymos recognizes applicable browser-based universal opt-out preference signals, including Global Privacy Control, where required by law.

Thymos does not use GPC-signaling visitors' information in a manner inconsistent with an applicable legally recognized opt-out preference.

10. Your Washington Rights

For Consumer Health Data subject to the MHMDA, you may have the right to:

Because PHI and other healthcare information may be exempt from MHMDA, requests concerning your medical record may instead be handled under HIPAA, Washington healthcare privacy law, and the Thymos Provider Group Notice of Privacy Practices.

11. How to Exercise Your Rights

You may submit a request by contacting:

Email: privacy@thymoshealth.com
Phone: (415) 379-0745

You may also use Thymos's applicable privacy or account-deletion request mechanisms.

We may take commercially reasonable steps to authenticate your identity.

You are not required to create a new account solely to exercise MHMDA rights, although Thymos may ask you to authenticate through an existing account where appropriate.

12. Deletion Requests

Where the MHMDA applies to information covered by a valid deletion request, Thymos will:

Where covered Consumer Health Data exists in archived or backup systems, deletion may be delayed for the period permitted by Washington law, which may be up to six months following authentication of the request.

A MHMDA deletion request does not require destruction of PHI, medical records, or other information that is exempt from MHMDA and retained pursuant to healthcare law.

13. Response and Appeal Process

Thymos will respond to authenticated requests within the period required by applicable law.

If Thymos declines to act on an applicable MHMDA request, you may appeal by contacting:

privacy@thymoshealth.com

Please include "Washington Privacy Appeal" in the subject line.

Thymos will respond to an appeal within the period required by law and, where required, provide information about how to contact the Washington Attorney General if the appeal is denied.

14. Security

Thymos limits access to Consumer Health Data to workforce members and processors where reasonably necessary for the applicable purpose.

We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Consumer Health Data.

15. Changes to This Policy

If Thymos proposes to collect, use, or share additional categories of Consumer Health Data subject to the MHMDA, or to use such data for materially additional purposes, Thymos will update this Policy and obtain affirmative consent before the new collection, use, or sharing where required by law.

16. Contact

Thymos Health Privacy Office
Thymos Health, Inc.
Thymos Provider Group, PC
Attn: Nilesh Bhandari, COO and Privacy/Security Officer
679 S. Eliseo Dr.
Greenbrae, CA 94904

Phone: (415) 379-0745
Email: privacy@thymoshealth.com

See also our Privacy Policy.