Consumer Health Data Privacy Policy | Living Well by Prosoma

Prosoma, Inc. Prosoma.com/us
Version 1.0
Effective Date: November 4, 2026
Last Updated: November 6, 2026

1. About This Policy

This Consumer Health Data Privacy Policy explains how Prosoma, Inc. ("Prosoma," "we," "us") handles consumer health data about residents of Washington, Nevada, and Connecticut, and the rights those residents have. It applies to information collected through Prosoma.com/us, our forms on Facebook and Instagram, the Living Well app, and our care navigation and coaching services.

"Consumer health data" means personal information that identifies, or can reasonably be linked to, your past, present, or future physical or mental health. On our services, this can include the fact that you sought cancer support from us.

This Policy does not cover protected health information governed by HIPAA, which is described in our Notice of Privacy Practices. In general, information becomes protected health information once you receive care services from us. Our general Privacy Policy describes our other practices.

2. Consumer Health Data We Collect and Why

Category	Examples	Purpose and how we use it
Contact details linked to a request for cancer support	Name, email address, phone number, date of birth, and preferred call time you give us when you request a callback, book a call, or submit one of our forms	To contact you, arrange the call or enrollment you asked for, and send related messages
Health information you choose to share before enrolling	Your cancer type, treatment stage, or support needs, if you mention them to a Care Navigator	To understand whether our programs fit your needs and to begin intake
Enrollment status	Whether you contacted us and whether your intake has started	To manage your enrollment and, for people who arrive from our ads, to measure which ads work (see Section 4)
Website activity on health-related pages	Pages viewed, buttons clicked, and a random identifier stored in your browser	To understand and improve how our website works
Ad click identifiers	The identifier added to a link when you click one of our Google or Meta ads	To measure which ads lead people to contact us
Inferences	The inference that you or someone you support may be living with cancer	This follows from your use of our services. We use it only for the purposes listed above.

3. Where We Get It

From you, when you complete our forms, message us, or speak with a Care Navigator
From your browser or device, through our website and analytics tools
From Meta, when you complete one of our forms on Facebook or Instagram
From a caregiver or family member who contacts us on your behalf

4. Consumer Health Data We Share and Who Receives It

Recipient (category)	Consumer health data shared	Why
Service providers (processors): care coordination (Tellescope), website hosting and security (Cloudflare), analytics (Mixpanel, PostHog)	The data in Section 2 needed for each provider's task	To operate our website and services on our behalf, under written contracts that limit their use of the data
Clinical enrollment partner (OpenLoop Health)	Contact details, insurance information, and relevant health information	To verify eligibility and arrange a clinical order when you enroll in a program that requires one
Advertising platforms (Google, Meta)	Ad click identifier, a hashed (scrambled) email address and phone number, and the fact that you contacted us or that your intake started; for Meta, also your IP address and browser type	To measure our ads. For Washington, Nevada, and Connecticut residents, we share this only with your opt-in consent.
Legal and safety recipients	Only what is required	When required by law or to protect someone's safety
Successor in a business transfer	The data in Section 2	If Prosoma is part of a merger or acquisition, subject to this Policy

Affiliates:Prosoma sp prosoma.com/en is our European affiliate however, no consumer health data is shared with this entity.

What we don't do:

We do not sell consumer health data.
We do not use geofencing around health care facilities to track people, collect health data, or send health-related messages or ads.
Our website does not use advertising or social-media pixels, so third parties cannot use our website to collect information about your online activities over time and across other websites.

5. Your Consent

We collect consumer health data only to provide the service you request, such as responding to your callback request, or with your consent. We ask for your separate consent before sharing it for any other purpose, including advertising measurement. You can withdraw your consent at any time, using the "Your privacy choices" link in our website footer or by contacting us (Section 7). Withdrawing consent stops future sharing but does not affect sharing that already happened.

Where do you live?

Washington, Nevada, and Connecticut

If you live in Washington, Nevada, or Connecticut, opt in here before we collect consumer health data. You can turn this off later to withdraw that consent.

6. Your Rights

If you are a resident of Washington, Nevada, or Connecticut, you have the right to:

Confirm and access: find out whether we collect, share, or sell your consumer health data, and get a copy of it
Know who received it: get a list of the third parties and affiliates we have shared it with, and how to contact them
Withdraw consent: stop our collection or sharing that is based on your consent
Delete: ask us to delete your consumer health data. We will also tell our service providers and other recipients to delete it. Copies in backups are deleted on the backups' normal cycle.
Appeal: challenge our decision if we deny your request

Connecticut residents also have the rights described in Section 10.2 of our Privacy Policy, including the rights to correct their data and to opt out of targeted advertising.

We will not treat you differently for exercising these rights.

7. How to Exercise Your Rights

Email: support@prosoma.com, with "Consumer Health Data Request" in the subject line
Mail: Prosoma, Inc., Attn: Privacy Officer, 2108 N St #13468, Sacramento, CA 95816
Opt-out switch: the "Your privacy choices" link in our website footer, to withdraw consent to advertising measurement

We verify your identity by matching information we already hold, and ask for more only if needed. An authorized agent may submit a request with your written permission. We respond within 45 days. If we need more time, we may extend this by up to 45 more days and will tell you why. Requests are free, up to twice in any 12-month period.

Appeals: If we deny your request, reply to our decision or email support@prosoma.com with "Appeal" in the subject line within 60 days. We will respond in writing within 45 days and explain our reasons. If you disagree with the outcome, you may contact your state Attorney General:

Washington: Office of the Attorney General, www.atg.wa.gov
Nevada: Office of the Attorney General, ag.nv.gov
Connecticut: Office of the Attorney General, portal.ct.gov/ag

8. How We Protect Consumer Health Data

Only employees and contractors who need consumer health data for the purposes above can access it, and they are bound by confidentiality obligations. We encrypt it in transit and at rest. Ad click identifiers and hashed contact details are deleted 90 days after the ad click.

9. Changes to This Policy

If we make a material change, we will post the updated Policy with a new effective date and notify you by email or on our website before the change takes effect. If a change would allow us to use or share your consumer health data in a new way, we will ask for your consent first.

10. Contact Us

Prosoma, Inc.

Attn: Privacy Officer

2108 N St #13468, Sacramento, CA 95816

Email: support@prosoma.com

Phone: 877-509-5978