Consumer Health Data Privacy Policy

Introduction

Certain state laws, including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each is amended, require companies that collect and process "consumer health data" to provide consumers a supplemental Consumer Health Data Privacy Policy.

“Consumer health data” is generally defined to include personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status, such as information about health conditions or diagnoses; bodily functions, symptoms, or measurements; reproductive or sexual health; and inferences about your health that are derived from other information.

This Consumer Health Data Privacy Policy (“Health Privacy Policy”) describes how Tracy Anderson Mind and Body, LLC ("Tracy Anderson," "we," "us," or "our") collects, uses, shares, and protects your consumer health data in connection with our assessments, personalized programs, and related services that collect consumer health data (together, our “Programs”), and the rights you have with respect to that data.

This Health Privacy Policy supplements our general Privacy Policy, and where the two conflict with respect to consumer health data, this Health Privacy Policy governs. This Health Privacy Policy applies only to users located in the United States.

Consumer Health Data We Collect

Depending on the Programs you participate in and how you interact with us, we may collect the following categories of consumer health data, which you provide directly to us or which we infer from the information you provide.

Health Conditions, Injuries, and Treatment. Information about injuries, surgeries, or physical limitations, the areas of your body that are affected, whether you are receiving medical or rehabilitation care, and whether a healthcare provider has advised you to become more physically active.

Reproductive and Hormonal Health. Information about menstruation, pregnancy, the postpartum period, perimenopause, or menopause, and related areas such as the pelvic floor.

Bodily Functions, Fitness, and Measurements. Information about your energy, stress, sleep, and recovery; your movement history, fitness level, and how your body responds to exercise; and body measurements, such as height, weight, and circumference measurements.

Inferences. Consumer health data we derive or infer from the information you provide, such as profiles or classifications reflecting how hormonal or physiological factors may influence your body’s response to exercise, which we use to personalize your Program.

How We Collect Consumer Health Data

We collect consumer health data directly from you when you complete an assessment or otherwise participate in our Programs on our website. We do not purchase consumer health data from data brokers or collect it from third-party sources.

We also generate consumer health data through the inferences and profiles our systems derive from your responses. For example, if your answers indicate that your body responds differently to exercise during hormonal transitions, we may use that insight to tailor your Program. These inferences are based solely on information you have provided.

We collect and use consumer health data only with your consent and only as necessary to provide the Programs you have requested. We share consumer health data as described in “How We Share Your Consumer Health Data” below, and we will obtain your separate consent before sharing it for any other purpose.

How We Use Your Consumer Health Data

We may use your consumer health data for the following purposes:

Providing Our Programs. To create and deliver the personalized Programs you have requested, including using your assessment responses and the inferences we derive from them to develop your personalized profile and to build the individualized workout path that Tracy and her team have designed for you.

Improving and Developing Our Programs. To maintain, improve, and develop our Programs, including to refine our personalized workout paths and to design new Programs.

Communicating With You. To send you transactional emails that are part of the Programs you have requested and to respond to your questions and provide customer support.

Marketing, With Your Consent. Where you have separately opted in, and where permitted by applicable law, to send you personalized offers about other Tracy Anderson programs and products based on your consumer health data. You may withdraw your marketing consent at any time by emailing or writing to us at the contact information below. Withdrawing your marketing consent will not affect your Program.

Security and Fraud Prevention. To protect the security and integrity of our website and Programs, and to detect, prevent, and respond to fraud, unauthorized access, and other harmful or illegal activity.

Legal Compliance. To comply with applicable laws and legal obligations, to respond to lawful requests and legal process, and to establish, exercise, or defend our legal rights.

De-identified and Aggregated Data. To de-identify or aggregate consumer health data so that it can no longer reasonably be linked to you, and to use and disclose that de-identified or aggregated information for any lawful purpose, including to understand trends, conduct research and analytics, and develop and improve our Programs, products, and services. We will maintain and use de-identified data only in de-identified form, we will not attempt to re-identify it, and we contractually require any recipients of de-identified data to do the same.

How We Share Your Consumer Health Data

We share your consumer health data to the extent necessary to deliver our Programs. We may share it with service providers (processors) who perform functions on our behalf and are contractually obligated to use your data only as we direct and to maintain its confidentiality and security. These include independent trainers, nutritionists, and program developers who help design and deliver our Programs, our website hosting and technology platform providers, our email service provider, and cloud storage or data infrastructure providers that support our Programs.

We may share your consumer health data with the following affiliates for the purposes outlined in this Health Privacy Policy: (i) T.A. Studio New York, LLC; (ii) T.A. Studio City, LLC; and/or (iii) Tracy Anderson Private Training, LLC.

We may also share your consumer health data in connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants, and similar requests), to enforce any applicable terms of service or policies, and to protect or defend our business, the Programs, our rights, and the rights of our users or others.

We Do Not Sell Your Consumer Health Data

We do not sell consumer health data. We do not share consumer health data with advertising networks, data brokers, or other third parties for targeted advertising, and we do not permit third parties to collect it over time and across different websites or online services when you visit our assessment or Program pages.

Your Privacy Rights

Depending on where you live, you may have some or all of the following rights regarding your consumer health data. We will not discriminate against you for exercising them.

Right to Know and Access. To confirm whether we are collecting, sharing, or selling your consumer health data, to access that data, and to receive a list of all third parties and affiliates with whom we have shared or sold it, along with an email address or other online means to contact them.

Right to Correct. To review your consumer health data and request that we correct any inaccuracies.

Right to Delete. To request that we delete your consumer health data. We will delete it from our records, including archived or backup systems, and notify our affiliates, processors, contractors, and any other third parties with whom we have shared it to do the same.

Right to Withdraw Consent and Stop Processing. To withdraw your consent to our collection and processing of your consumer health data at any time, and to request that we stop collecting, sharing, or selling your consumer health data. You may withdraw your consent by emailing or writing to us at the contact information below, and you may withdraw your Program consent and any marketing consent separately. Withdrawal applies going forward and does not affect processing that occurred before it. If you withdraw your consent to our collection and use of your consumer health data or request deletion, we will no longer be able to provide your personalized Program, because our Programs depend on the health-related information you share.

To exercise these rights, please email us at taonlinestudio@tracyandersonmethod.com or contact us at Tracy Anderson Method, 241 East 59th Street, New York, NY 10022, United States. We will verify your identity and process your request as required by law. You do not need to create an account to submit a request. We will respond to your requests free of charge, except that, where permitted by law, we may charge a reasonable fee for requests that are manifestly unfounded, excessive, or repetitive. Please allow up to forty-five days for a response. If we need additional time, we may extend the response period once by up to forty-five additional days and will notify you of the extension and the reason for it within the initial period. Where required by applicable law, we will complete deletion requests within thirty days after verifying your request, except that deletion from archived or backup systems may be delayed as permitted by law. If we deny your request, you may appeal that denial by contacting us at the address above, and we will respond to your appeal in writing within forty-five days. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including the Washington State Attorney General at www.atg.wa.gov/file-complaint or the Nevada Attorney General at ag.nv.gov.

Changes to This Policy

We may update this Health Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Health Privacy Policy on this website, update the "Last Updated" date, notify you of material changes by email or by a prominent notice on this website, and provide any other notice required by applicable law.

Contact Us

Should you have any questions about our privacy practices or this Health Privacy Policy, or if you would like to exercise any of the rights available to you, please email us at taonlinestudio@tracyandersonmethod.com or contact us at Tracy Anderson Method, 241 East 59th Street, New York, NY 10022, United States.