Plants for Health
Consumer Health Data Privacy Policy
Version 2.1 — effective August 31, 2026
This policy explains how we handle consumer health data, as that term is defined in the Washington My Health My Data Act and in comparable laws such as the Nevada consumer health data law. It applies in addition to our Privacy Notice. Where the two differ in respect of consumer health data, this policy applies.
If you are a resident of Washington or Nevada, this policy sets out rights you have and how to exercise them.
1 Who we are
Plants for Health B.V., Stadhouderslaan 77, 3583 JE Utrecht, the Netherlands. Registered with the Dutch Chamber of Commerce under number 93914369. Contact: [email protected].
We are established in the Netherlands. This means the European General Data Protection Regulation applies to everything we do with your data, in addition to the laws of your own state. In practice this gives you more protection than the law of your state requires, not less.
2 What we treat as consumer health data
We take a deliberately broad view, and treat the following as consumer health data:
- the safe fit declaration you give before you enrol — that you are 18 or older; that you are not pregnant or breastfeeding and are not planning to become pregnant during the program, or you have discussed taking part with your doctor and they support it; that you are not underweight and are not losing weight without intending to, or you have discussed taking part with your doctor and they support it; that you have no surgery or medical procedure planned during the program, or you have discussed taking part with your doctor and they support it; and that you do not have, and have not had, an eating disorder or a disordered relationship with food, or you have discussed taking part with your doctor or your own practitioner and they support it — and the fact that you gave this declaration;
- the medication declaration you give before you enrol — that if you use any prescription medication, or have a condition that is monitored by a doctor, including but not limited to a rheumatic condition, immunosuppressants, corticosteroids, blood thinners, or diabetes medication, you have discussed taking part with your doctor — and the fact that you gave this declaration;
- the program understanding declaration you give before you enrol — that all medical decisions stay with you and your own doctor, that you will not start, stop or change any medication because of the program, that you will tell your own doctor you are taking part, and that you will contact your own doctor rather than wait if your symptoms are new, worsening or severe — and the fact that you gave this declaration;
- anything about your health, symptoms, medication, diet or wellbeing that you choose to post in our Community;
- anything about your health that you choose to tell us in an email or a support message;
- the fact that you enrolled in, or enquired about, a program concerned with inflammation, or signed up to our newsletter through a page about a specific condition;
- the fact that you registered for a webinar about inflammation or about a specific condition;
- inferences that could be drawn about your health from which of our emails you opened and which lessons you completed.
The last three items matter. If you buy a program about inflammation, sign up to our newsletter through a page about a specific condition, or register for a webinar about one, that could suggest something about your health even though you never told us a diagnosis. The same is true of which lessons you completed and which of our emails you opened. We treat all of that as consumer health data.
3 What we do not collect
We do not ask you what your condition is, and we do not ask you for a diagnosis, your medication, your weight, your BMI, or any test result. Nothing in our program depends on your telling us. There is no intake questionnaire and no medical file.
For the safe fit, medication and program understanding declarations described in our Terms and Conditions, we record only that you confirmed them, on which date, and against which version of our Terms. We do not record why, and we do not ask.
The declarations are worded so that they do not reveal a condition. Each situation they mention can be confirmed in either of two ways: because it does not apply to you, or because it does and you have discussed taking part with your doctor, who supports it. Either way you tick the same box, and nothing about your health follows from the fact that you ticked it. Under the General Data Protection Regulation we therefore process that record on the basis of the performance of our agreement with you, and not on the basis of your consent. The Washington My Health My Data Act defines health data more broadly than the GDPR does, so under this policy we treat the record as consumer health data all the same, and give you the rights in clause 8 in respect of it.
We do not provide individual consultations or individualised advice, so we have no reason to hold a health record about you.
You can take part in the Community under a name of your choosing. Other participants see only that name. We recommend using one if you intend to write about your health. This does not make your contributions anonymous to us — we know which account posted them, and this policy therefore continues to apply to them.
4 What we collect, and why
| What | Why | Where it is held |
|---|---|---|
| That you gave the safe fit, medication and program understanding declarations, with date and version | To show that we asked, and that you confirmed, before enrolling you | You complete these on our website, in a form built with Gravity Forms and hosted by mijn.host in the Netherlands. That entry is permanently deleted within 2 days. The confirmation record is sent via Zapier to SharePoint, where Microsoft provides our long-term record |
| What you post in the Community | To run the Community and answer your questions | Kajabi |
| What you tell us by email | To answer you | Microsoft |
| That you bought a program about inflammation | To give you access and to take payment | Kajabi and Stripe |
| Whether you opened our program emails, and which lessons you completed | To see whether the program materials reach you and work | Kajabi |
| That you signed up to our newsletter, and whether you opened our newsletter emails | To send our newsletter, and to see whether it reaches you | Brevo |
We do not use consumer health data to make decisions about you other than those described here, and we do not use it for automated decision-making that has legal or similarly significant effects.
5 Where it comes from
Directly from you: in the declarations you complete on our website, in the Community, and in messages you send us. From how you use the learning platform, our newsletter and our program emails. We do not buy health data about you from anyone, and we do not obtain it from any third party.
6 Who we share it with
We share consumer health data only with service providers who process it on our behalf, under a written contract that requires them to protect it, to follow our instructions, and to pass on the obligations in this policy.
| Provider | What they process | Role |
|---|---|---|
| Kajabi | Account data, enrolment, Community posts, course progress, video viewing, and automated program emails to participants | Learning platform, community and program email |
| Microsoft | Email correspondence with us, documents, and the long-term record of your declarations, via SharePoint | Email provider and document storage |
| mijn.host | Hosts our website, including the declaration form. Entries are permanently deleted within 2 days | Website hosting. Established in the Netherlands |
| Zapier | The confirmation record of your declarations, briefly, while it is routed from our website to SharePoint | Automation between our systems. Established in the United States |
| Brevo | Your email address, and whether you opened our emails | Sending our newsletter. Established in France |
| Stripe, with Sold through Link, LLC as merchant of record | Payment data and the name of the product you bought. Payment data is not health data. The name of the product can suggest why you bought it, so we pass on nothing beyond what the payment itself requires | Payment processing. The merchant of record is not our processor: it decides for itself what it does with the payment data it needs in order to take your payment, issue your receipt and meet its own tax and anti-fraud obligations. Established in the United States |
| Zoom | Your name and email address when you register for a webinar, and the recording of the webinar itself. Participants are not visible or audible in our recordings: we record only the presentation | Webinar hosting. Established in the United States |
| Cloudflare | Technical signals from your browser, including your IP address, when you submit a form on our website. No health data | Protecting our forms against automated abuse, using Cloudflare Turnstile. Established in the United States |
Kajabi, Microsoft, Zapier, Zoom and Cloudflare are established in, or have parent companies in, the United States. We have a written data processing agreement with each of them. Where personal data is transferred out of the European Economic Area, that transfer is safeguarded by the European Commission's Standard Contractual Clauses, or by another mechanism recognised under the GDPR. Brevo (France) and mijn.host (the Netherlands) process your data within the European Economic Area.
We do not sell your consumer health data, and we have never done so. If that were ever to change, we would first obtain your separate written authorization, which is a distinct step from consent and which you could revoke at any time.
We do not share your consumer health data with advertising platforms. We do not place advertising pixels on our website, and we do not use analytics or tracking tools that identify or profile individual visitors. Our hosting provider keeps aggregate visit statistics, such as the total number of visits, for technical and security purposes only; these are not linked to an individual and are not used to draw any conclusion about a visitor's health. Nothing about your health, and no inference about it, is transmitted to any third party for advertising or measurement. Cloudflare Turnstile, which protects our forms against automated abuse, does not follow you across websites, is not an advertising platform, and sets no advertising cookies. Our Cookie Policy lists every cookie in use.
We may disclose data where the law requires it, or to protect someone from serious harm.
7 Your consent
The three declarations are not based on your consent. You give each of them by its own tick box when you enrol, separately from your acceptance of our Terms, and we process the record of them on the basis of the performance of our agreement with you, for the reason set out in clause 3.
What your consent does cover. Anything you choose to tell us about your health, or post in the Community, we process only with your explicit consent. You give that consent at the moment you choose to share it, not at checkout. You are never required to share anything about your health, and nothing in the program depends on your doing so. Where you choose to, you do so on your own initiative, and not sharing has no effect on your access.
Kajabi sends automated emails to participants as part of running the program. Every one of them contains an opt-out link. For anything beyond running the program — in particular using health-related inferences for marketing — we ask for your separate, specific opt-in consent, and we do not make it a condition of purchase.
You can withdraw consent at any time, by emailing [email protected] or using the opt-out link in our emails. Withdrawing consent stops future use. It does not affect what we did before you withdrew it, and it does not affect data we must keep in order to provide a program you are enrolled in.
8 Your rights
You have the right to:
- know and access what consumer health data we hold about you, where we got it, and who we shared it with;
- withdraw your consent to our collection and sharing of it;
- have it deleted.
To exercise any of these, email [email protected] with your request and the email address you use with us. We may ask you to confirm your identity, and we will ask only for what we need to do that.
We will respond within 30 days. In exceptional cases we may need more time, up to 45 days in total; if so, we will tell you within the first 30 days and explain why.
On deletion. If you ask us to delete your consumer health data, we will delete it from our active systems and instruct every service provider that holds it to do the same, including in their archives and backups. Posts you made in the Community will be removed. We will confirm when this is done. Where a law requires us to keep specific records, we will tell you what we kept and why.
If we refuse a request, we will explain why and tell you how to appeal. To appeal, reply to our response. We will decide the appeal within 30 days, under the same exceptional-cases extension described above. If we refuse your appeal, you may complain to the Attorney General of your state.
9 How long we keep it
| What | How long | Why |
|---|---|---|
| Your declaration entry in our website form | Up to 2 days, then permanently deleted | Only long enough to send the confirmation record on to our long-term record |
| The confirmation record that you gave the declarations | 7 years after your access ends. We keep this record separately, so it survives the deletion of your account | To show we asked, for as long as a claim could be brought |
| Community posts | Indefinitely, unless you ask us to remove them | So later participants can read earlier discussions. You can ask for removal at any time |
| Email correspondence | 2 years after our last contact | To handle follow-up questions and complaints |
| Account, lesson progress and email engagement | Duration of your access | To run the program and answer your questions while you take part |
| Newsletter subscription and email engagement | Until you unsubscribe, then removed | To send our newsletter and see whether it reaches you |
These periods are our own choice, not a legal minimum. If you ask us to delete something sooner, we will, unless a law requires us to keep it.
10 How we protect it
We limit access to consumer health data to the people who need it to do their work. Access is granted individually and reviewed periodically. Data is encrypted in transit and at rest by our providers. We require our providers to maintain comparable measures. Where health information reaches us by email, it is held in our email system and we do not copy it into other systems or documents.
Our Community is visible to other participants. Contributions remain there after a participant's access ends, so that later participants can read earlier discussions. Our Terms ask all participants to treat what others share as confidential, and you can take part under a name of your choosing.
You can ask us to remove your contributions at any time, including after your access has ended. Email [email protected]. We will do it and confirm when it is done.
11 Children
Our products and services are for adults. You must be 18 or older to buy from us, and the safe fit declaration asks you to confirm that. We do not knowingly collect consumer health data from anyone under 18, and we do not knowingly sell to anyone under 18. If you believe we hold data about a child, tell us at [email protected] and we will delete it.
12 Changes to this policy
If we change this policy, we will publish the new version with a new version number and a new effective date. We will not use consumer health data we already hold for a materially different purpose without asking you first.
13 Contact
Plants for Health B.V., Stadhouderslaan 77, 3583 JE Utrecht, the Netherlands