1. Who this policy applies to
This policy applies to a natural person who is a Washington resident, or whose consumer health data is collected in Washington, when acting in an individual or household context and where MHMDA applies. It is separate from Mosey’s general Privacy Policy and does not mean that Mosey collects every category of information that Washington law may define as consumer health data.
2. Consumer health data Mosey collects and why
Depending on the Mosey features you choose and the permissions you grant, we may collect the following categories:
- Step and activity totals: to display activity progress, operate step-based features, determine daily step tiers and calculate activity-based rewards and the daily Step Multiplier.
- Activity dates and timestamps: to attribute activity to the correct day, apply daily limits and milestones, investigate activity/reward errors and maintain accurate reward records.
- Activity source information: limited information identifying the supported source or device from which activity was received, where available, to operate integrations, troubleshoot discrepancies and protect service integrity.
- Activity-derived reward and integrity information: records or inferences needed to determine whether activity qualifies for rewards, detect duplicated, manipulated or artificial activity, prevent fraud and protect Mosey and its members.
Mosey does not collect medical records, diagnoses, medication information, genetic data or reproductive/sexual health information merely because you use the step-reward features. We do not use HealthKit or Health Connect data for advertising or ad targeting.
3. Sources of consumer health data
Consumer health data may come from: information or permissions you provide; supported device sensors and operating-system activity services; Apple Health/HealthKit where you authorize access; Health Connect where you authorize access; and Mosey service records generated when activity is processed for the purposes described in this policy.
4. How Mosey uses and processes the data
Authorized activity information is received through supported device or health-platform interfaces, associated with your Mosey account where needed, and processed to display activity, calculate daily progress, determine rewards and Step Multiplier tiers, investigate errors, prevent fraud and maintain security. Access is restricted to systems, processors, contractors and personnel for whom access is necessary for the disclosed purpose or to provide a product or service you requested.
We may also process information where permitted by law to prevent, detect, protect against or respond to security incidents, identity theft, fraud, malicious or deceptive activity, illegal activity, or threats to system integrity.
5. Consumer health data Mosey shares
Current categories shared with third parties or affiliates under MHMDA: Mosey does not currently share consumer health data with third parties or affiliates for their own purposes, advertising, targeted advertising, profiling or sale. Moseyaround Limited currently has no affiliate with which it shares consumer health data.
Service providers acting as processors may process limited activity data, account identifiers, timestamps and integrity/security information on Mosey’s behalf where necessary to host, secure, support or operate the requested service. Processor access is limited by contract and instructions and is not permission to use the data for the processor’s own advertising purposes.
Raw Apple Health/HealthKit and Health Connect data is not provided to advertising networks, advertising SDKs or offerwall providers for advertising, targeting or profiling.
If Mosey proposes to share consumer health data in a way for which Washington law requires consent, we will disclose the categories of data, purpose and categories of recipients and obtain the required consent before sharing.
6. Sale of consumer health data
Mosey does not sell consumer health data. We do not currently intend to sell it. If that practice ever changed, Mosey would first provide the disclosures and obtain the separate, valid authorization required by applicable law. Providing Mosey’s service would not be conditioned on signing an authorization to sell consumer health data where prohibited by law.
7. Your Washington rights
Subject to MHMDA, you may:
- confirm whether Mosey is collecting, sharing or selling consumer health data about you;
- access consumer health data about you;
- obtain a list of third parties and affiliates with whom Mosey has shared or sold your consumer health data, together with an available email address or other online contact mechanism for those recipients;
- withdraw consent to future collection or sharing where processing relies on your consent; and
- request deletion of consumer health data about you.
You will not be unlawfully discriminated against for exercising rights provided by MHMDA.
8. How to make a request
Email [email protected] with the subject Washington Consumer Health Data Request. Please identify the right you want to exercise and provide the email address associated with your Mosey account, if you have one.
We may use commercially reasonable steps to authenticate you before acting. We will not require you to create a new account solely to exercise these rights, although we may ask you to use an existing account or provide additional information reasonably necessary to authenticate a request.
9. Timing and charges
We will respond without undue delay and, in all cases required by MHMDA, within 45 days after receiving your request. Where reasonably necessary because of complexity or the number of requests, that period may be extended once by up to another 45 days; if so, we will tell you within the initial period and explain why.
Information provided in response to a consumer request is free of charge up to twice annually. Manifestly unfounded, excessive or repetitive requests may be handled as permitted by applicable law.
10. Deletion
When a valid deletion request applies, Mosey will delete the covered consumer health data from its records and network and notify affiliates, processors, contractors and other third parties with whom the data was shared so that they can honor the deletion request as required by law. Where covered data exists in archived or backup systems, deletion may be delayed only as permitted by law and, for a Washington MHMDA request, not beyond six months from authentication of the deletion request.
11. Appeals
If we refuse to act on your request, you may appeal by emailing [email protected] with the subject Washington Consumer Health Data Appeal. The appeal process is available without requiring a new account.
We will respond to an appeal within 45 days of receipt with the action taken or not taken and an explanation. If an appeal is denied, we will also provide a method through which you may contact the Washington State Attorney General to submit a complaint.
12. Consent and withdrawal
Where Washington law requires consent to collect consumer health data, the request will be specific to the collection and purpose. Where Washington law requires consent to share consumer health data, sharing consent will be requested separately and distinctly from collection consent. Consent will not be obtained through acceptance of general Terms or deceptive interface designs.
You may withdraw health-platform permissions through your device or health-platform settings and may contact us at [email protected] to withdraw consent to future collection or sharing where applicable. Withdrawal does not require Mosey to reverse processing that was lawful before withdrawal.
13. Security
Mosey restricts access to consumer health data to personnel, processors and contractors where access is necessary for the disclosed purpose or to provide a service you requested. We maintain administrative, technical and physical safeguards designed to protect the confidentiality, integrity and accessibility of consumer health data, appropriate to the nature and volume of the data.
14. Healthcare-facility geofencing
Mosey does not use geofences around entities providing in-person healthcare services to identify or track consumers seeking healthcare, collect consumer health data from them, or send health-related notifications, messages or advertisements to them.
15. Changes to this policy
We will update this policy before collecting, using or sharing additional categories of consumer health data, or using consumer health data for additional purposes, where MHMDA requires disclosure and affirmative consent. The current effective and review dates appear at the top of this policy.
16. Contact
Privacy requests and appeals: [email protected]
Legal enquiries: [email protected]
Moseyaround Limited, 66 Paul Street, London, EC2A 4NA, United Kingdom.
