Consumer Health Data Privacy Notice

1.What this notice covers

This notice is issued by Vanguard Performance LLC for Filia and covers “consumer health data”: personal information that identifies your past, present or future physical or mental health, including laboratory results, health history, reproductive or sexual health information, and anything inferred from them. It supplements the Privacy Policy and, where the two differ, gives you whichever is more protective. Information held by Quest Diagnostics or the ordering physician’s medical group under HIPAA is covered by their notices, not this one; see How HIPAA Applies to Filia.

2.The consumer health data we collect

Laboratory orders and results, with the laboratory’s reference ranges and any note from the ordering physician.
The health history you choose to give us: goals and concerns, reproductive history where relevant, diagnoses, medications, allergies, family history, prior laboratory work and procedures, and lifestyle.
Laboratory reports you upload from elsewhere, and the values read from them.

Cycle observations you record or import, and why you are tracking: bleeding, cervical mucus, ovulation-test results, basal body temperature, pain, mood, sleep, hot flashes, hormonal birth-control use, symptoms and notes, and the cycle phases, patterns and fertility estimates derived from them.

Supplement purchases, to the extent a purchase reveals something about your health.

Inferences we make from the above to show you educational context beside a result. These inferences are shown to you and to no one else.
Your consents and preferences about all of the above.

3.Where it comes from

You, when you create an account, fill in your health history, record observations, upload a document or place an order.
The ordering physician’s medical group and Quest Diagnostics, which release your order and results to us under the HIPAA Authorization you sign at checkout.
The laboratory named on a specialty test, for tests it analyzes.
No one else. We do not buy health data, receive it from data brokers, or infer it from your browsing.

4.Why we collect it

To show you, if you use cycle tracking, estimates built from your own observations.

To deliver the testing you ordered: passing your order to the ordering physician, producing the requisition, receiving and showing you the results.
To give the ordering physician what they need to review your order.
To show you educational context beside your results.
To extract reported values from a lab-report PDF you upload using Google Cloud’s HIPAA-eligible Vertex AI service, for you to review before adding them to your history.
To keep your records available to you for as long as you keep your account.
To meet legal obligations and to keep the service secure.
For nothing else. In particular, not for advertising, not for sale, not for profiling, and not for training artificial-intelligence models.

5.Who we share it with

We share consumer health data only with your consent, given at checkout or in the feature that uses it, and only with these categories of recipient, each under a contract that limits it to the stated purpose:

Junction (Adept Labs, Inc.) and the ordering physician’s medical group, to review and authorize your order and receive the results. They may also use your contact details to send service communications related to your testing.
Quest Diagnostics (Quest Diagnostics Incorporated), to collect and analyze your specimen. They may also use your contact details to send service communications related to your testing.
The laboratory named on a specialty test, for that test. They may also use your contact details to send service communications related to your testing.
Google Cloud Vertex AI — HIPAA-eligible service, to extract reported values from the lab-report PDF you upload, including any identifying and health information it contains, for your review.
Service providers that host our systems and send our messages on our behalf, which receive only what their task requires and may not use it for anything else.
A court or authority with a valid, specific legal order, after we have reviewed it and, where the law allows, challenged it.

Affiliates: Vanguard Performance LLC operates Vanguard as well as Filia. No other affiliate exists, and consumer health data is not used by one brand to market the other.

We do not sell consumer health data. A sale would require your separate, signed authorization under the laws this notice addresses, and we will not ask for one.

6.Your rights

To confirm whether we hold consumer health data about you and to receive a copy of it.
To receive a list of the third parties and affiliates with which we have shared it, with contact details for each.
To withdraw any consent you gave for its collection or sharing. Withdrawing consent to share with the ordering physician or the laboratory means we can no longer deliver a pending order, and we will tell you so before acting.
To have it deleted, including from our service providers and from backups on their normal schedule, and to have a record of the deletion request kept so it can be shown to have been honoured.
To appeal a decision we make about a request, and if the appeal fails, to complain to the attorney general of your state.

Write to info@myfilia.com, or use the deletion and download controls in Settings. We verify the request, act within 45 days, and tell you if we need up to 45 more. We do not deny you a service or charge you differently for exercising a right.

7.Location

We do not collect precise location and we do not use geofencing around any healthcare facility, including Quest Diagnostics patient service centers, for any purpose. The lab-location preference in your account is a choice you make, not a location we detect.

8.How to reach us

Privacy requests: info@myfilia.com
Mail: Vanguard Performance LLC, 2901 Cleveland Ave., Suite 102, Santa Rosa, CA 95403