1. What We Mean by Consumer Health Data
For purposes of this Policy, “Consumer Health Data” includes personal information that identifies, relates to, describes, or may reasonably reveal or permit an inference concerning an individual's physical or mental health, bodily functions, symptoms, or wellness characteristics.
This may include information that is classified as:
- consumer health data;
- health information;
- sensitive personal information;
- sensitive personal data; or
- special-category personal data
under applicable privacy law.
Use of the term “Consumer Health Data” in this Policy does not mean that QINGHE is a healthcare provider or that information processed by QINGHE constitutes a medical record.
2. Consumer Health Data We Collect
Depending on how you use QINGHE, we may collect the following categories.
Assessment Responses
Information you provide in response to questions concerning matters such as:
- perceived energy and fatigue;
- sleep and rest;
- digestion and appetite;
- temperature preferences;
- sweating;
- skin or dryness;
- sensations of heaviness or discomfort;
- environmental sensitivity;
- subjective emotional tendencies;
- perceived reactions to seasons or climate; and
- other everyday wellness characteristics included in the assessment.
Derived Constitution Information
QINGHE may derive information from your responses, including:
- constitution scores;
- primary constitution classification;
- secondary constitution tendencies;
- assessment summaries;
- personalized explanatory content; and
- generated report content.
These are TCM-inspired wellness classifications and are not medical diagnoses.
Health-Related Support Information
If you voluntarily include health-related information when contacting customer support, that information may also be treated as Consumer Health Data.
Please avoid sending medical records or unnecessary medical information to QINGHE Support.
3. Sources of Consumer Health Data
We obtain Consumer Health Data from:
You directly
when you answer assessment questions or voluntarily provide health-related information.
QINGHE's assessment system
when the system derives constitution scores, tendencies, or report content from the responses you submitted.
We do not intend to obtain medical records from hospitals, physicians, insurers, pharmacies, or government health databases.
4. Why We Collect Consumer Health Data
We collect and use Consumer Health Data for the following purposes:
To Provide the Assessment You Requested
Including to:
- process your questionnaire responses;
- calculate constitution scores;
- identify constitution tendencies;
- display your assessment result; and
- generate personalized assessment content.
To Provide a Purchased Report
Where you purchase a report, Consumer Health Data may be processed as necessary to:
- generate the report;
- associate the report with the relevant transaction;
- deliver the report;
- restore access where that functionality is offered; and
- resolve report-generation problems.
To Provide Support
Where necessary to investigate:
- a missing report;
- an incorrect delivery;
- a technical error;
- a report-access problem; or
- another issue raised by you.
To Protect the Service
Consumer Health Data may be processed where necessary to maintain the integrity and security of QINGHE, prevent abuse, investigate incidents, or satisfy applicable legal obligations.
5. What We Do Not Use Consumer Health Data For
QINGHE does not intend to use individual Consumer Health Data to:
- diagnose disease;
- provide medical treatment;
- make healthcare eligibility decisions;
- determine insurance eligibility;
- determine employment eligibility;
- determine credit eligibility;
- build unrelated advertising profiles;
- target advertising based on a user's constitution result;
- sell health-related audience segments;
- provide individual health data to data brokers; or
- make decisions producing legal or similarly significant effects about a user.
7. Categories of Recipients
Consumer Health Data may be disclosed to the following categories of processors, contractors, or service providers where reasonably necessary:
Hosting and Cloud Infrastructure Providers
To transmit, process, or temporarily store assessment information and deliver the service.
Database or Storage Providers
Where needed for report generation, restoration, security, or limited retention.
Report-Generation Services
Where necessary to calculate or assemble the content requested by the user.
Email or Delivery Providers
Only where necessary to deliver a purchased report or service communication.
Email delivery systems should receive the minimum Consumer Health Data necessary for delivery.
Customer-Support Providers
Only where Consumer Health Data is necessary to resolve a user-requested issue.
Security and Technical Service Providers
Where necessary to protect QINGHE or investigate a security or technical incident.
Professional or Legal Advisers
Where disclosure is reasonably necessary to comply with law or establish, exercise, or defend legal rights.
QINGHE will identify specific affiliates that receive Consumer Health Data in this Policy where required by applicable law.
8. Advertising Platforms
QINGHE's production architecture should keep Consumer Health Data separated from advertising systems.
We do not intend to provide the following information to Meta, Google advertising products, TikTok advertising products, advertising networks, data brokers, or similar advertising platforms:
- individual assessment answers;
- individual constitution scores;
- primary constitution result;
- secondary constitution tendencies; or
- personalized report content.
General conversion events may be measured without including Consumer Health Data.
For example, an advertising or analytics system may receive that an assessment was completed or a purchase occurred, but should not receive that a particular user was classified as “Dampness-Heat,” “Qi Deficiency,” or another constitution.
9. Sale of Consumer Health Data
QINGHE does not sell Consumer Health Data.
We do not exchange individual assessment responses or constitution results for monetary consideration.
We do not intend to engage in transactions that constitute the sale of Consumer Health Data under applicable consumer health privacy laws.
If our practices change in the future, we will provide any notice and obtain any authorization required by applicable law before such a change takes effect.
10. Consent
Where required by applicable law, we obtain consent before collecting Consumer Health Data.
The consent request will describe:
- the categories of Consumer Health Data being collected;
- why the data is being collected;
- how it will be used;
- relevant categories of recipients; and
- how consent may be withdrawn.
Where applicable law requires consent to sharing that is separate from consent to collection, we will request that consent separately.
A general agreement to our Terms of Use does not replace a separate Consumer Health Data consent where separate consent is legally required.
11. Withdrawal of Consent
Where processing is based on consent, you may withdraw consent for future processing as permitted by applicable law.
Withdrawal does not retroactively invalidate processing that lawfully occurred before withdrawal.
Withdrawal may make it impossible for QINGHE to continue providing features that require the Consumer Health Data concerned.
To withdraw consent, contact:
payments@qinghewell.com
12. Consumer Health Data Rights
Depending on applicable law, you may have the right to:
- confirm whether QINGHE collects, shares, or sells Consumer Health Data concerning you;
- access Consumer Health Data concerning you;
- obtain information about third parties or affiliates with whom applicable Consumer Health Data has been shared;
- withdraw consent to future collection or sharing;
- request deletion of Consumer Health Data; and
- appeal certain refusals of privacy requests where applicable.
To exercise these rights:
payments@qinghewell.com
You are not required to create a new QINGHE account solely to submit a legally protected Consumer Health Data request.
We may reasonably verify your identity before fulfilling a request in order to protect your information from unauthorized disclosure or deletion.
13. Washington Consumers
Where the Washington My Health My Data Act applies, Washington consumers may exercise rights provided by that Act, including rights concerning confirmation, access, withdrawal of consent, and deletion.
Where required, an access response may include information concerning third parties or affiliates with whom Consumer Health Data has been shared or sold.
QINGHE will respond to authenticated requests within the period required by applicable law.
For qualifying Washington requests, this generally means without undue delay and within 45 days, subject to a legally permitted extension where reasonably necessary.
Where a valid deletion request applies, QINGHE will take required steps to delete covered Consumer Health Data from applicable systems and notify relevant processors, contractors, affiliates, or third parties as required.
Deletion from archived or backup systems may take additional time where permitted by applicable law.
Consumers may also have the right to appeal a refusal to act on a request.
14. European Economic Area and United Kingdom
Consumer Health Data may constitute special-category data under European or UK data-protection law.
Where required, QINGHE will obtain explicit consent or rely on another legally permitted condition before processing such information.
Where processing relies on consent, you may withdraw that consent for future processing.
The general rights and contact procedures described in our Privacy Policy also apply.
15. Mainland China
Information concerning an individual's health may constitute sensitive personal information under the Personal Information Protection Law of the People's Republic of China.
Where applicable, QINGHE will process such information only for a specific and necessary purpose with appropriate protective measures.
Separate consent will be obtained where legally required.
Users will also receive legally required information concerning the necessity and potential impact of sensitive-information processing.
Where covered Consumer Health Data is transferred outside mainland China, any additional notice, separate consent, contractual, certification, security-assessment, or other applicable legal requirements will be addressed before the relevant transfer occurs.
16. Retention and Deletion
QINGHE follows a data-minimization principle for Consumer Health Data.
Consumer Health Data should not be retained indefinitely simply because it was submitted.
Our production retention architecture is intended to distinguish among:
Raw Assessment Responses
These should be retained only as long as reasonably necessary to calculate the result, generate the requested report, provide limited restoration or troubleshooting, and satisfy applicable legal requirements.
Constitution Results
These may be retained for a limited period where necessary to provide the requested report or restore access to it.
Purchased Reports
Where a report-access feature is provided, data may be retained for the period reasonably necessary to provide that feature.
Deidentified Information
We may retain information that has been properly deidentified so that it cannot reasonably be linked to an identifiable consumer, provided it is handled consistently with applicable law.
When we receive a legally valid deletion request, we will delete covered Consumer Health Data as required and direct applicable processors or other recipients to do the same where required.
17. Security
We apply safeguards appropriate to the sensitive nature of Consumer Health Data.
These measures are intended to include:
- restricting access based on legitimate need;
- minimizing the Consumer Health Data collected;
- separating health-related data from advertising systems;
- limiting processor access;
- protecting communications and storage using appropriate technical safeguards;
- maintaining security and incident-response procedures; and
- reviewing third-party data practices before allowing access to Consumer Health Data.
No method of electronic processing is completely secure, but we seek to apply safeguards appropriate to the volume and sensitivity of the information involved.
18. Health Data Breaches
If QINGHE experiences unauthorized acquisition, access, or disclosure of Consumer Health Data, we will investigate the incident and provide notifications where required by applicable breach-notification law.
Depending on applicable law and circumstances, required notifications may include affected consumers and relevant regulators.
19. Changes to Health Data Practices
We will not rely solely on a privacy-policy update to materially expand Consumer Health Data collection, use, or sharing where applicable law requires prior consent.
Where required, before collecting a new category of Consumer Health Data or using existing Consumer Health Data for a materially new purpose, QINGHE will:
- provide the required disclosure; and
- obtain the legally required consent.
20. Contact and Exercise of Rights
Questions or Consumer Health Data requests may be directed to:
KANG FU LIN LIMITED
payments@qinghewell.com
Please do not send additional medical records or unnecessary health information when submitting a privacy request.
QINGHE may request limited information necessary to securely authenticate the request.