Attorney

OWEN | VANDERBRUG
1001 FOURTH AVENUE
SUITE 3200
SEATTLE, WA 98154

CHD PRIVACY POLICY

This Consumer Health Data Privacy Policy is published pursuant to the Washington My Health My Data Act (RCW 19.373) and applies to consumer health data as defined by that Act. This policy is separate from and in addition to the Spiriteric general Privacy Policy.

Categories of Consumer Health Data Collected

Spiriteric may collect the following categories of consumer health data in the course of providing its services:

• Information about a consumer’s past, present, or future physical health status voluntarily disclosed during session intake or during sessions (such as medical conditions, symptoms, medications, or health concerns)
• Information about a consumer’s past, present, or future mental health status voluntarily disclosed during session intake or during sessions (such as mental health diagnoses, emotional wellbeing, trauma history, or psychological concerns)
• Information related to a consumer’s bodily functions, vital signs, or physical symptoms as voluntarily disclosed by the consumer
• Information about health-related services or products a consumer has obtained or is seeking, as voluntarily disclosed

Purpose of Collection: Consumer health data is collected solely to provide the spiritual guidance and coaching services requested by the consumer, to maintain session records for legal documentation and quality assurance, and to fulfill content usage rights as authorized under the consumer’s applicable service agreement.

Categories of Sources

Consumer health data is collected from the following sources:

• Directly from the consumer through client intake forms submitted via Acuity Scheduling
• Directly from the consumer during sessions conducted via Zoom video conferencing
• From session recordings and AI-generated transcripts produced by Zoom and Fathom AI
• From email, text, or other communications initiated by the consumer

Categories of Consumer Health Data Shared

Spiriteric may share consumer health data with the following categories of third parties solely for the purposes of service delivery, session recording, and business operations:

• Video conferencing and recording providers: Zoom Video Communications, Inc. (for session delivery and recording)
• AI transcription providers: Fathom Video, Inc. (for session transcription)
• Scheduling platform: Squarespace, Inc. / Acuity Scheduling (for intake form data)

Spiriteric does not sell consumer health data. Spiriteric does not share consumer health data for advertising or marketing purposes. Spiriteric does not share consumer health data with any parties other than those listed above, except as required by law (including mandatory reporting of child abuse, elder abuse, or imminent threats of harm).

Consumer Rights

Under the Washington My Health My Data Act, you have the following rights regarding your consumer health data:

• Right to Confirm and Access: You may confirm whether Spiriteric is collecting, sharing, or selling your consumer health data and access such data, including a list of all third parties and affiliates with whom the data has been shared
• Right to Withdraw Consent: You may withdraw your consent for the collection and sharing of your consumer health data at any time
• Right to Deletion: You may request deletion of your consumer health data. Upon receiving a verified deletion request, Spiriteric will delete the data from its records, archives, and backups and notify applicable third parties to honor the deletion request

Important Limitation: Session recordings and transcripts may contain consumer health data that you voluntarily disclosed during a session. Deletion of consumer health data from session recordings may not be technically feasible without destroying the entire recording. In such cases, Spiriteric will work with you to determine a reasonable accommodation, which may include restricting access to the recording rather than deletion of the recording itself. Content that has been published under the content usage rights granted in your service agreement cannot be recalled, but Spiriteric will make reasonable efforts to remove or anonymize health-related content from published materials upon request.

How to Exercise Your Rights

To exercise any of the rights described in this policy, submit a request to Spiriteric using the contact information provided at the top of the Terms of Service page. Spiriteric will verify your identity before processing your request and will respond within 45 days. If additional time is required, Spiriteric will notify you of the extension and the reason for it.

Changes to This Policy

Spiriteric may update this Consumer Health Data Privacy Policy as necessary to reflect changes in data practices or legal requirements. The current version is always available via the link on the Spiriteric homepage.

Last Updated 2026 March 25